1. Sustainable Foreign Investment
by SWFs and SOEs
A report prepared for UNCTAD WIR2014
Lilac Nachum
Professor, Globalization and Multinational Companies

2. Foreign investment by government-controlled and/or owned entities – such as Sovereign Wealth
Funds (SWFs) and State-Owned Enterprises (SOEs) - has increased considerably in recent years
(UNCTAD, 2013). The sustainability and accountability of this investment has raised serious
concerns among policy makers and its regulation has become a major focus of national and
international economic policy (Truman, 2007). The distinctive nature of sovereign investors
appears to restrain the applicability of regulations directed towards TNCs, and to require a
different approach that addresses their specific characteristics (Szamosszegi and Kyle, 2011;
Sauvant, Sachs and Jongbloed, 2012). Moreover, the patterns of this investment are
overwhelmingly South-North, that is, the majority of sovereign investors originate in developing
countries, and most of their investment is directed to developed countries (UNCTAD, 2013). The
gap that tends to exist in the perception of sustainable investment and sustainability practices
between developing and developed countries further intensifies fears in host countries regarding
the consequences of this investment.
Whereas these concerns arise in relation to all the foreign activities of government-controlled
entities, they are particularly heighted when it comes to FDI. The deeper involvement in host
countries and the higher commitment that FDI represents increases the potential impact of this
investment relative to portfolio investment. FDI has bearing to a large number of local
stakeholders, extending beyond the narrower impact of portfolio investment that affects mostly
shareholders and financial markets (Goldstein and Razin, 2006; Kinda, 2012). Negative
consequences originating in the lack of transparency and accountability can thus have more
devastating consequences – for both the host and home countries involved.
These concerns have led to proliferation of attempts to control and regulate the foreign
investment of state-owned and/or controlled entities – by both individual countries, TNC
networks, and globally. Individual countries and regions, notably the US and the EU, South
Africa, Japan, have introduced voluntary codes of conducts, and promoted the adoption of best
practices by SWFs, advocating transparent governance practices and greater accountability to
local stakeholders. These attempts have focused on voluntary self-regulation, with the goal of
engaging sovereign investors in discussions of appropriate investment objectives and procedures
(Rose, 2008).
Global attempts have been bolder and more formal. Backing of the IMF led to the creation in
2008 of the International Forum of Sovereign Wealth Funds (IFSWFs) and the subsequent
introduction of a set of principles and practices designed to guide the investment activities of
SWFs, known as the Santiago Principles (The International Working Group of Sovereign Wealth
Funds, 2008). The Principles consist of 24 voluntary guidelines in relation to the structure,
governance, and management of SWFs, and address legal, institutional and governance
frameworks related to their activities. As of 2013, 26 IMF members with SWFs signed on the
Principles.
There have also been several attempts to measure the sustainability of SWFs investment, and
provide a comparative measure of their performance, as a basis for the setting of global standards
of sustainable investment. Notable among these are the Linaburg-Maduell Transparency Index of
the Sovereign Wealth Fund Institute, the Revenue Watch Institute’s Resource Governance Index,
the Bagnall-Truman scoreboard, and Transparency International’s Corruption Perceptions Index.

3. These measures rate SWFs based on their level of transparency and accountability, and are
highly correlated (Bagnall and Truman, 2013; Sovereign Wealth Fund Institute, 2013a).
Underlying these efforts is the fear that investment by government-controlled entities could harm
host countries. The sheer size of this investment, coupled with potential political influences,
creates anxiety regarding its possible consequences, and these are further exacerbated by the lack
of transparency and the opaqueness of most SWFs.
In 2012, the combined assets under management of SWFs accounted for about $5.5 trillion, more
than double the size of assets held by hedge funds and private equity funds combined (Sovereign
Wealth Fund Institute, 2013b). These assets are projected to reach $12 trillion by 2015 (Jen,
2007), and are likely to further increase by the many SWFs currently underway. 21 countries are
considering establishing SWFs (Santiso, 2012). FDI by SOEs is also of considerable size, and
accounted in 2012 for one tenth of global FDI outflows (UNCTAD, 2013). Such large holdings
controlled by governments are at variance with market-based global economy and financial
systems (Truman, 2007; Summers, 2007), leading to severe concerns regarding their impact on
market behavior and risk attitudes (Wong, 2009). Sovereign investors are accountable only to the
governments that own them and are not subject to external transparency requirements. This
deprives shareholders and other stakeholders of knowledge of their activities and the ability to
exercise their voice in their decisions, and exacerbates concerns regarding the consequences of
their investment (Tsania, Ahmadovb and Aslanlic, 2010). Such concerns, particularly in the
developed world that hosts most of this investment, are propelled by the fact that most world
sovereign investors originate in emerging markets and are controlled by undemocratic authorities
(The Economist, 2012). These regimes tend to be less committed to sustainability and
transparency principles, and their standards on these measures tend to be lower than those
common in the developed world (Aizenman and Glick, 2008).
Government controlled entities are thus increasingly important actors in markets that were
designed for transactions involving private actors, and the existing regulatory structure
concerning the sustainability of their investment appears short of meeting the demands of
regulating their activities (Rose, 2008).
At the same time, however, foreign investment by sovereign investors offer many benefits for
both home and host countries. The latter actively compete for these investments, due to its sheer
size, the typically long-term investment horizons, and the unique risk bearing capacities. The
desire to attract this investment has become particularly apparent in the 2008 financial crisis and
its aftermath (Truman, 2010). As evidenced by the countercyclical actions of SWFs during the
financial crisis, these funds have the potential to act as a stabilizing force. For home countries,
foreign investments by sovereign entities diversify their economies and lower their vulnerability
to risk originating in e.g. adverse macroeconomic developments, shifts in commodity prices or
exchange rates. It also helps spread income across generations (Baker, 2010; Fernandes, 2011).
This state of affair creates an urgent need to introduce appropriate policy measures that will
address the sustainability of foreign investment, and particularly of FDI, by sovereign investors,
such that the potential benefits of this investment could fully materialize. Addressing these
concerns has become a matter of specific urgency as the 2015 deadline for the implementation of

4. the Sustainable Development Goals (SDGs) is approaching. The SDGs seek to embrace the three
dimensions of sustainable development – in relation to environmental, social, and governance
standards - and their inter-linkages, as they apply to all stakeholders involved. The sustainable
investment by government-owned and/or controlled entities is of particular importance in this
context.
Proper regulatory environment that imposes greater transparency, improves the governing and
monitoring structure, and furthers accountability is in the interest of all involved, including the
investors, home and host countries. Such measures would increase the credibility of the
investment and will lessen negative attitudes that harm investment opportunities and deprive the
materialization of their benefits. For instance, UK’s Co-operative Bank publicly declared
refraining from doing business with firms in which SWFs that do not meet levels of
accountability and legitimacy are involved (Bendell et al., 2009).
For such measures to be effective, it is vital that they are designed as a set of global uniform
standards rather than introduced at the country level. There are several reasons for the supremacy
of multilateral agreements on sustainable investment. For one, attempts by individual countries
could result in both over- and under-regulation. The latter could originate in fear of losing out to
other countries in the competition to attract investment, or else in investors exercising their
negotiating power to create a race to the bottom in the regulatory requirements (Epstein and
Rose, 2009; Wong, 2009). Over-regulation could be the result of nationalist and protectionist
pressures exercised on national policy makers, which tend to be more powerful and influential at
the national than international level. A global arrangement is desired also because it would
create a forum for all parties involved to voice their concerns, including both host and home
countries. Lastly, a uniform regulatory system will expose investors to a single set of regulatory
requirements, rather than confront them with different and potentially conflicting requirements of
individual countries. This will lower the compliance cost of the investors and the monitoring
costs of host countries (Wong, 2009).
Such attempts however have to address some major challenges, sole among them is probably the
harmonization of sustainability requirements across countries (Matten and Moon, 2008).
Perceptions of what constitutes sustainable investment originate in deep cultural and historical
features of countries and as such are resistant to change (Argondona and Hoivik, 2009). As
government-owned and controlled entities, the perceptions of sovereign investors reflect the
political values and political systems of their home countries (Rose, 2008). Countries that have
weak traditions of sustainable investments are unlikely to adhere to higher international
standards. The challenge is exacerbated by the patterns of sovereign investment, whereby the
home and host countries are predominantly developing and developed countries respectively
(UNCTAD, 2013), increasing the gap in the perception of sustainable investment.
Furthermore, at the core of the concerns in relation to sovereign investors is distrust regarding
their intentions. Mere formal disclosure requirements would not resolve this issue, as they are as
meaningful as the creditability of the disclosing party. There is thus the challenge of addressing
the credibility concerns, rather than imposing transparency requirements, and putting in place a
credible method to ascertain the truth of disclosed information, arguably a challenging task
(Wong, 2009; Dixon, 2013).

5. Indeed, some sovereign investors such as China have strongly resisted calls for further regulation
of SWFs, and have threatened to withdraw their investments from countries that tighten their
rules (Forbes, 2007). Other SWFs expressed concerns regarding transparency expectations on the
ground that these jeopardize the financial results of their investment (Rose, 2008).
There is also the challenge of striking a careful balance between regulating sovereign investors
and constraining their ability to contribute to the societies in which they invest. In seeking to
assure that this investment is not politically motivated, sovereign investors are driven to act as
profit maximizing institutions and may be deprived of the ability to invest towards social goals
(Zee, 2012).
In addition, the natural place for the introduction of a multilateral agreement would be under the
auspice of the WTO. Such an arrangement has the enforceability advantage and provides a
mechanism for dispute resolution. However, failure to reach agreements at the WTO on other
matters, notably a multilateral framework for FDI generally, illustrates the difficulties of
harmonizing the diverse needs of the large number of participants in these agreements, and
questions the viability of this solution.
Alternatively, there is the possibility of voluntary best practices, designed specifically to address
the nature of sovereign investors, perhaps administered by the World Economic Forum. Such an
attempt could be modeled after the United Nations’ Principles for Responsible Investment,
which were introduced in 2006 to guide the sustainability of portfolio investment. The problem
with such voluntary measures is that those most of need of them often do not join, jeopardizing
the accomplishment of their purpose.
A voluntary agreement will also put some countries at a disadvantage. Countries that have
significant political power and large amounts of two-way flows between them and home
countries of the sovereign investors have more power to bring about the adoption of codes of
best practices. Countries with less leverage are likely to be more susceptible to risks posed by
political motives of sovereign investors (Rose, 2008).
Sustainability of Portfolio Investment
Most of sovereign foreign involvement, notably investment undertaken by SWFs and pension
funds, is portfolio investment. According to UNCTAD estimates, in 2012 portfolio investment
accounted for about 95% of SWF foreign investment (UNCTAD, 2013)1. The impact of this
investment is thus apparent particularly on financial markets.
Sovereign portfolio investors differ from most other financial investors in several important
ways. One is their sheer size. As noted earlier, the magnitude of SWFs investment exceeds this
of hedge funds and private equities combined. The six largest SWFs are comparable to the
largest institutional investors in the world (Sovereign Wealth Fund Institute, 2013b). This size
implies that their behavior can significantly affect financial market dynamics and influence
1 Foreign investment by SOEs is FDI.

6. market prices. Moreover, the government ownership and backup in the face of negative
developments may distort the risk attitudes of sovereign investors and cause them to evaluate
investment targets in a manner that misrepresent their true market value, thus distorting financial
markets. The opaqueness and limited disclosure of investment policies, typical of many
sovereign investors, could have particularly severe consequences for financial markets. Reliable
information is of paramount value for the functioning of financial markets, as it builds the
foundation of trust and credibility that are fundamental for these markets. The lack of it raises
investors’ uncertainty and may distort their judgment, causing market volatility and raising the
cost of capital in the face of perceived elevated risk (Wong, 2009).
At the same time, the government ownership typically entails that sovereign portfolio investors
carry no liabilities and have little redemption risk, and these enable them to take a longer-term
investment outlook than most other institutional investors. They typically do not modify their
investment allocations in response to short-term volatility, thus increasing stability of financial
markets. Further, sovereign investors usually refrain from high leverage and can provide
liquidity to the capital market, as has been shown by the countercyclical actions of SWFs during
the financial crisis (Bolton, Samama and Stiglitz, 2011).
These distinctive characteristics of sovereign portfolio investors create a need for a special
regulatory framework that will guide their sustainable investment. The main international
attempt to guide the sustainability of portfolio investment (of both private and state-owned
investors) is the UN PRI (UN PRI, 2012). The PRI is a voluntary framework introduced in 2006
that specifies environmental, social and corporate governance (ESG) principles that should be
incorporated into the management of financial institutions. As of 2013, 1,229 investment
institutions have become signatories to the UN PRI, including also a few SWFs. By becoming
signatories, these SWFs take on sustainability responsibilities that are on par with those of
private financial investors.
It is not clear whether sovereign investors can and act as private entities and given their
distinctive attribute whether the same instrument can govern private and government-owned
entities.

7. References
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Argondona A. and Hoivik H.W. 2009. Corporate social responsibility: One size does not fit all.
Journal of Business Ethics 89: 221-234.
Bagnall A.E. and Truman E.M. 2013. Progress on Sovereign Wealth Fund Transparency and
Accountability: An Updated SWF Scoreboard. Peterson Institute for International Economics,
Policy Brief 13-19
Baker C. 2010. Sovereign Wealth Funds. in J.R. Boatright (Ed.) Finance Ethics: Critical Issues in
Theory and Practice. Hoboken, NJ: Wiley, pp. 252-271.
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Investing. Columbia University Press, New York, NY.
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Each Other. CSRwire Talkback blog, Sep 17.
Dixon A.D. 2013. Enhancing the Transparency Dialogue in the 'Santiago Principles' for
Sovereign Wealth Funds. Mimeo, University of Bristol.
The Economist. 2012. State Capitalism: Special Report, January 21st.
Epstein R.A. and Rose A. 2009. The regulation of Sovereign Wealth Funds: The virtues of going
slow. University of Chicago Law Review 76(111) 111-135.
Fernandes N. 2011. Sovereign Wealth Funds: Investment choices and implications around the
world. Working Paper. IMD International.
Forbes. 2007. China Investment Corp warns Western governments against protectionism. Dec.
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8. The International Working Group of Sovereign Wealth Funds (IWG). 2008. Generally Accepted
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Policy Reactions. Oxford University Press, Oxford and New York.
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Wealth Fund Institute, Las Vegas, NV.
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Accountability. Peterson Institute for International Economics, Policy Brief 07-6
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International Economics, Washington, D.C.

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Sovereign Wealth Funds: Remarks on the assessment, rankings and benchmarks to date. Public
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10. Box. Norway SWF: An Exemplar of SWF Sustainable Foreign Investment
SWFs vary considerably in terms of their sustainability behavior. The Sovereign Wealth Fund
Institute Transparency Index ranks world SWFs based on their transparency and provides an
indication of their ethical agenda and standards (Sovereign Wealth Fund Institute, 2013a).
Norway SWF has received the highest score on the index every year since it was introduced in
2008. It has been recognized as a model of corporate governance and ethical behavior and its
conducts in these areas are considered best practices by international standards (Backer, 2010).
The SWF follows strict ethical standards of target selection, based on recommendations of the
Council on Ethics which was established specifically for the purpose of advising the SWF on
sustainable investment (Chesterman, 2008). It follows an open and rigorous process of censoring
and certifying targets based on their social, environmental, governance, and ethical conduct, and
has excluded several prominent firms from its investment universe because they did not meet its
sustainability standards.
Norway SWF is explicit in its intention to diffuse its principles of sustainable investment to
Norway firms and to the broader societies in which it invests. Its sheer size and visibility assists
it in achieving these goals. With market value of $700 billion in 2013, which exceeds the size of
Norway GDP, Norway SWF is the world’s largest (Sovereign Wealth Fund Institute, 2013b). It
holds minority stakes in more than 7,000 firms worldwide, and it is one of the largest
shareholders in many of them (Norway SWF, 2013). This gives the SWF the power to advocate
agenda that is in line with its own priorities and to affect the formation of responsible investment
principles.
The adoption of ethical standards and socially responsible principles by Norway SWF has
legitimized such behavior and facilitated its broader diffusion among Norwegian firms.
Vasudeva (2013) interviews with Norwegian firms show that they actively embrace the SWF’s
selection criteria in their global investment. An interviewee quoted in this study admitted that
investment targets excluded from the investment universe of the SWF because their corporate
governance practices did not meet the SWF’s standards are automatically excluded from their
firm’s investment as well. Analyses of a large data set of cross-border equity investments
undertaken by Norwegian firms revealed that the SWF’s judgment regarding the corporate
governance standards of target firms significantly increases the likelihood that the cross-border
investments of Norwegian firms comprise responsible targets. It appears that the SWF’s
standards exert normative pressures on Norwegian firms to which they respond by mimicking
the SWF principles (Vasudeva, 2013).
The adoption of the SWF principles by Norway firms in their foreign investment has given
impetus to the SWF efforts to facilitate the adoption of universal responsible governance
principles. There are several indications of the means via which these principles have diffused
beyond the SWF and Norway firms and have modified corporate behavior in host countries. For
instance, the CSR managers of a large Norwegian financial institution quoted in Vasudeva study
described how the SWF’s ethical guidelines have affected his industry, and have increased the
recognition that ‘… we need to think about other issues than just short-term and traditional

11. financial questions.’ (Vasudeva 2013, p. 1670). Another interviewee reported pressure of his
firm’s clients to follow the SWF’s standards.
The SWF is explicit in stating its intention to diffuse its ethical standards in the broader societies
in which it operates and globally:‘…[t]he [sovereign wealth] Fund can also play a role as a
model for other funds or investors. The size of the Fund may induce many other investors to
track the Fund’s activities closely. The decision whether and how to introduce ethical guidelines
in the Fund may send an important signal and may cause other funds to follow suit. …The Fund
can also exert influence indirectly through the market. By explicitly communicating a decision
not to buy a particular share, the Fund can send signals to company executives, other market
participants and a company’s customers.’ (Norway Ministry of Finance, 2012; Norway SWF,
2013).
The SWF adopts several principles in order to exercise its impact in host countries and globally.
For one, it publicly announces its decisions to refrain from investing in firms that do not meet its
social responsibility standards (Government Pension Fund Global, 2010). Further, vigorously
guards the ethical behavior of the firms in which it invests, and uses the instruments it has as a
financial investor to exercise its voice on issues of corporate governance, ethics, and human
rights (Bowers, 2008). Recently the SWF announced plans to take a more active monitoring role
in its biggest shareholdings where it will seek to influence the choice of directors in order to
secure compliance with its sustainability agenda.
Norway SWF illustrates how a sovereign investor can adhere to high standards of sustainable
investment, thus challenging the view that government ownership in inconsistent with
sustainable investment. It also shows how SWFs, as a form of institutional investor with
typically minority ownership and no control rights via voting shares or board seats, can exercise
their power to actively influence the standards of their investment targets. Norway SWF also
provides an example of how SWFs can combine the roles of participants in global financial
markets with this of a regulatory stakeholder, using the ‘soft power’ that government-owned
entities have to impose normative pressure and their ability to instill change in sustainability
standards of firms and the broader societies in which they invest, thus securing both economic
and regulatory returns on their investment (Backer, 2013; Vasudeva, 2013). It conform to the
view that sovereign investors, as government entities designed to invest a country’s wealth for
the benefit of future generations, should be held to higher sustainability standards, and should
lead societal efforts to instill sustainable behavior of business (Zee, 2012).
References
Backer, L.C. 2010. Sovereign wealth funds as regulatory chameleons: The Norwegian sovereign
wealth funds and public global governance through private global investment. Georgetown
Journal of International Law, 41: 425-492.
Backer, L.C. 2013. Sovereign Investing and Markets-Based Transnational Rule of Law Building:
The Norwegian Sovereign Wealth Fund in Global Markets. Forthcoming, American University
International Law Review.

12. Bowers, S. 2008. Norway's pension fund publishes vote data, revealing stand on ethical issues.
The Guardian, November 3, p. 27.
Chesterman S. 2008. The turn to ethics: Divestment from multinational corporations for human
rights violations: The case of Norway’s sovereign wealth fund. American University
International Law Review 23: 577-616.
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Ministry of Finance, Oslo.
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Oslo, Norway.
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Investment Management, Oslo.
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Wealth Fund Institute, Las Vegas, NV.
Sovereign Wealth Fund Institute. 2013b. Sovereign Wealth Fund Asset Allocation 2013.
Sovereign Wealth Fund Institute, Las Vegas, NV.
Vasudeva G. 2013. Weaving together the normative and regulative roles of government: How
the Norwegian Sovereign Wealth Fund's responsible conduct is shaping firms' cross-border
investments. Organization Science, 24(6): 1662-1682.
van der Zee E. 2012. Sovereign Wealth Funds and Socially Responsible Investing: Do’s and
Don’ts. European Company Law, Kluwer Law International, Special Issue on CSR and SRI 9(2):
141-150.