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UPP’s Investment Exclusion Policy: What to Know
- Investments
- Reports and disclosures
- UPP’s Investment Exclusion Policy: What to Know
Understanding investment exclusions
At UPP, we aim to deliver long-term value to members by actively managing risks to our investments, including financially material environmental and social risks. One way we do this is through investment exclusions.
What are investment exclusions?
We may choose to exclude a company from our investment portfolio or sell a company when:
- There is evidence of severe adverse social or environmental impacts that could create undue risk to UPP’s investment portfolio, and
- Interventions like engagement, stewardship, or other actions have not been, and are unlikely to be, effective in preventing, mitigating, or remedying that harm.
UPP’s Investment Exclusion Policy outlines when and how we make these decisions.
How does the Policy work?
Our Investment Exclusion Policy has two parts:
1. General Parameters
Criteria defining the circumstances under which exclusions may apply to our investments (available on our website as an Appendix to the Investment Exclusions Policy).
The Investment Exclusions Policy and General Parameters are developed by UPP Management and approved by the Board of Trustees. This approval follows a thorough review of factors, including the complexity of global business operations and variations in disclosure standards.
2. Excluded entities list
An internal list of specific entities meeting the criteria within our General Parameters. These “entities” could include financial instruments, companies or entities, groups of companies, economic activities, business practices, governments, geographic exposures or asset types. We have excluded entities under each general parameter.
Management develops and regularly updates this list of specific excluded entities with support from third-party research and shares it with UPP’s investment partners, who regularly certify compliance or report exposure to excluded entities. Our investment teams use internal monitoring tools to support this process.
Does UPP disclose its excluded entities?
No. We publicly disclose our exclusion criteria but do not name specific companies or entities to maintain transparency while respecting confidentiality and market sensitivity.
Examples of investment exclusions
Thermal coal
Why is it excluded?
Thermal coal is one of the highest greenhouse gas emitting fossil fuels, with alternatives already in place and a weak long-term financial outlook. These factors pose financially material risks to our portfolio.
How do we apply it?
We use a third-party data provider to flag companies that meet one or more of our conditions for thermal coal mining or coal-based power generation, as defined in Appendix A of our General Parameters.
Why coal but not oil and gas?
While we don’t categorically exclude oil and gas, we are working to support a responsible, real-economy transition to net-zero. For our own portfolio, we are committed to reaching net-zero emissions by 2040. Our multi-pronged approach includes:
- Evaluating investments through our Climate Transition Investment Framework
- Investing in climate solutions such as renewable energy and sustainable energy infrastructure
- Engaging with companies and policymakers to support credible, science-based transition plans
Severe adverse social or environmental impacts
Why is it excluded?
Companies causing or contributing to severe adverse impacts—such as human rights violations or environmental degradation—often carry high legal, regulatory, and operational risk, which in turn presents heightened investment risk.
How do we apply it?
We work with credible third-party research providers to identify companies with documented involvement in severe impacts, particularly in conflict-affected and high-risk areas. We also actively monitor companies where adverse impacts have been identified, but do not yet meet our exclusion threshold.
What are conflict-affected and high-risk areas (CAHRAs)?
These are regions experiencing heightened risks of harm due to armed conflict, widespread violence, or political instability. Armed conflict may involve wars between states, civil wars, insurgencies, or other forms of violent struggle. High-risk areas may also be marked by weak governance, institutional breakdown, repression, or insecurity. These conditions often lead to serious human rights abuses and violations of national or international law.*
Companies causing or contributing to these harms can expose themselves (and their investors) to material social and political risks and, in turn, financial risk.
In 2025, we added new specialist research capabilities to better identify and assess risks in these areas, which has supported additional exclusions under this category.
Does the policy apply the same to all investments?
The Policy applies across the entire portfolio, but the way exclusions are implemented can differ between public and private investments.
In public markets, changes to our General Parameters and the excluded entities list are shared with our investment partners, who regularly certify compliance or report any exposure to excluded entities. In private markets, UPP typically negotiates for the General Parameters in place at the time of the investment commitment to apply. These are long-term investments, often spanning over a decade, and we work with our partners to promote continued alignment when updates to the Policy occur.
Learn more
See our explainer on pooled versus segregated funds and how our responsible investing principles are applied in different public market investment structures.