ICBL-CMC submission to the Gjedrem Committee on the ethical guidelines
for the Government Pension Fund Global
Dear Chair and members of the Committee,
The International Campaign to Ban Landmines-Cluster Munition Coalition (ICBL-CMC) urges the Committee to preserve strong, comprehensive weapons criteria for the Government Pension Fund Global (GPFG) and ensure their effective implementation.
Our research identifies concerns about investments in companies involved in cluster munition production that demonstrate why both are necessary.
ICBL-CMC is a global civil society network working to eliminate antipersonnel mines and cluster munitions and uphold the rights of people affected by these weapons. Our work is grounded in the experiences of survivors and communities living with their consequences.
These weapons kill and injure civilians, obstruct access to land and livelihoods, and impede recovery long after conflicts have ended.
Norway has played a leading role in humanitarian disarmament, including in the
development of the Mine Ban Treaty and the Convention on Cluster Munitions. The Fund’s investment policy should reinforce Norway’s commitments under these treaties and its longstanding support for their universal acceptance.
Address gaps in implementation ICBL-CMC’s review of published holdings data from Norges Bank Investment Management (NBIM), the division of Norway’s central bank responsible for managing the GPFG identifies investments by the Fund in Solar Industries India Ltd as at 30 June 2026, and in LIG Nex1 Co Ltd, now renamed LIG Defense & Aerospace, and Bharat Dynamics Ltd as at 31 December 2025.
Cluster Munition Monitor 2026 documents these companies’ involvement in cluster munition development or production. These concerns involve substantial and continuing activities. Solar Industries’ subsidiary received a contract in 2025 for Pinaka cluster munition rockets, with a stated duration of eight to 15 years. LIG received a production contract for Haeryong missiles equipped with submunition warheads running from 2023 to December 2026. Bharat Dynamics is involved
in the development and production of the Pralay missile, for which a cluster warhead has been developed.
Our review also identifies a holding in Poongsan Holdings as at 30 June 2026, while
Poongsan Corp is excluded for cluster munition production. This raises a further question about whether screening adequately addresses parent companies and corporate group relationships.
These findings warrant prompt examination and action. They also demonstrate that retaining the weapons criteria on paper is insufficient. The framework needs systematic, ongoing research into producers, regular screening of holdings and prospective investments, and timely decisions when evidence of involvement emerges. Screening must also anticipate new producers of antipersonnel mines and cluster munitions.
Preserve the humanitarian basis of the criteria
The ethical framework should continue to address weapons whose normal use violates fundamental humanitarian principles. Restricting exclusions solely to weapons prohibited by treaties to which Norway is a party would weaken this approach. Norway’s treaty obligations provide an essential foundation, but they should not set the ceiling for its ethical investment standards. A weapon’s humanitarian consequences do not depend on Norway’s treaty membership, the producer’s nationality or its relationship with Norway’s allies. Although antipersonnel mines and cluster munitions would remain covered by Norway’s treaty commitments, this does not justify weakening the wider framework,
including the exclusion of nuclear weapons producers.
Norway’s security needs can be met while maintaining these ethical boundaries.
Investment in defence companies that do not undertake the excluded activities remains possible.
We therefore urge the Committee to recommend:
• Retaining comprehensive product-based exclusions covering antipersonnel mines,
cluster munitions and the other weapons covered by the established humanitarian
criteria, including nuclear weapons.
• Maintaining coverage of development and production of these weapons and their
key components, including through controlled entities, and ensuring appropriate
scrutiny of parent companies and corporate groups.
• Rejecting any narrowing based solely on Norway’s treaty membership or exceptions based on nationality, security partnerships or procurement relationships.
• Restoring effective exclusion procedures, supported by independent assessment by the Council on Ethics, systematic and adequately resourced research, and
transparent, timely decisions.
• Ensuring prompt assessment of the companies identified above and preventive
screening for emerging producers. Engagement should support companies in ending activities that justify exclusion; it should not replace exclusion while those activities continue.
At a time when humanitarian disarmament norms are under pressure, Norway’s leadership remains vital.
We urge the Committee to preserve strong weapons criteria and close implementation gaps so that the Fund does not benefit financially from the production of weapons that cause unacceptable humanitarian harm.
Yours sincerely,
Tamar Gabelinick, ICBL-CMC Director