Vestas
Topic: Biodiversity and nature loss
WHEB’s Objective: Limiting material negative social or environmental impacts
Company Objective: For Vestas to clarify its approach to biodiversity. Insights gathered during this engagement will inform longer-term behaviour change objectives.
Outcome: Reduced licensing delays; improved positioning as sustainability leader to attract new customers
Background: In early 2022, WHEB identified Vestas as having an elevated level of exposure to biodiversity impacts—both positive and negative—due to the nature of its operations and supply chain. Despite the clear interdependence between climate change and biodiversity, our initial attempts to engage the company on this issue were met with limited responsiveness. At the time, Vestas indicated that biodiversity was not a current priority, prompting concern that the company lacked a structured approach to managing these impacts.
We renewed our efforts via collaborative escalation in 2023, emphasising the importance of ensuring that the renewable energy transition avoids ecological harm and contributes positively to biodiversity via a collaborative escalation.
This prompted a more detailed response from the company in early 2023 with a detailed overview of current practices, including the use of bird and bat protection systems, environmental impact assessments, and the involvement of specialist consultants to develop a biodiversity strategy.
Activity: In the intervening time, like many corporates, Vestas has begun preparing to report in line with CSRD and published its double materiality assessment in 2024. Unfortunately, biodiversity was captured only under “impact materiality” but not “financial materiality”. We engaged with it to better understand how it had arrived at this conclusion and to encourage further action on biodiversity and nature loss.
Outcome
M1 Company acknowledges issue
Our March 2025 call with Vestas offered valuable insight into the company’s view on its biodiversity impacts. The company argued that its most material biodiversity impacts occur upstream in its supply chain, particularly through the mining of metals used in its turbines. These activities can lead to habitat destruction, pollution, and threats to biodiversity in ecologically sensitive regions. While Vestas does not operate the mines directly, it faces reputational and regulatory risks if sourcing is not managed responsibly.
Vestas does not currently consider biodiversity a financially material issue under double materiality assessment, though it does recognise its potential to become increasingly relevant to permitting processes and project development.
Vestas has explored frameworks such as SBTN and the TNFD LEAP approach, and has implemented location-specific assessments, particularly in upstream operations. However, it remains sceptical of standardised biodiversity assessment methodologies and hesitant to set biodiversity targets, citing challenges in measurement, materiality and uncertainty around impact.
Despite this caution, Vestas outlined active efforts to assess downstream impacts and highlighted various mitigation initiatives—such as minimising land clearance, protecting migration corridors, and restoring marine biodiversity in offshore wind projects.
Our next step is to write to the company reiterating the objectives we outlined during the call to:
- Encourage a clearer articulation—particularly in upcoming disclosures—of why biodiversity is not currently considered financially material.
- Explain how procurement and sourcing policies and practices are designed to mitigate upstream biodiversity risks.
- We will also suggest that greater transparency around how biodiversity considerations influence permitting and project development may prompt a future re-evaluation of biodiversity’s financial materiality as these factors gain prominence.
- Ask for case studies illustrating instances where standardised biodiversity data may be less applicable.
- Urge continued exploration of emerging biodiversity methodologies with the aim of setting credible, meaningful targets over time.
While Vestas’ current stance presents limitations, its openness to dialogue and ongoing assessment work is a positive step. We will continue monitoring progress and pushing for greater ambition in future engagements.
Ecolab - Hazardous Chemicals
Topic: Hazardous ChemicalsTopic: Hazardous Chemicals
WHEB’s Objective: Limiting material negative social or environmental impacts
Company Objective: For Ecolab to clarify a time-bound phase-out plan of substances of very high concern (SVHC) and increase revenue from safer alternatives.
Desired Outcome: Reduced environmental pollution and negative impacts to human and ecological health leading to reduced regulatory and reputational risk. Improved competitive advantage.
Background: The Investor Initiative on Hazardous Chemicals (IIHC), led by ChemSec and backed by over $18 trillion in AUM, engages with major chemicals producing companies to mitigate these risks. Ecolab, a global leader in water and hygiene solutions, has made strong progress over recent years and was ranked 4th in ChemSec’s 2024 ChemScore.
Activity: WHEB co-leads the Ecolab investor group. We arranged and chaired a company call and drafted a letter setting out the groups’ expectations and formalised engagement objectives:
- Transparency: Disclose global revenue and volumes of Substances of Very High Concern (SVHCs), aligning with CSRD and E2 Pollution standards.
- PFAS Evaluation: Provide an update on PFAS-related risks in the supply chain.
- Revenue Shift: Set a 2030 target to increase revenue from safer alternatives and publish a supporting strategy.
Outcomes
M2 - company shares or agrees to disclose information on the issue
These interactions represents an early stage in the current phase of dialogue. Ecolab is as yet to provide material updates against the objectives. It has however, reaffirmed its ambition to lead in hazardous chemical management and reach the top ChemScore ranking.
Ecolab also committed to improving near-term disclosure by publishing its Chemical Footprint Benchmark in 2025. We believe the company’s prioritisation of this issue reflects its material importance and are reassured by its ambition and progress to date.A follow-up to review progress is expected later in 2025.
Smurfit WestRock - Biodiversity
Topic: Biodiversity and nature loss; indigenous communities
WHEB’s Objective: Limiting material negative social or environmental impacts
Company Objective: For Smurfit WestRock to improve its Nature Action 100 Benchmark Assessment score by resolving discrepancies with the secretariat, strengthen engagement with indigenous communities and improve related disclosures.
Desired outcome: More accurate recognition of the company’s existing efforts to address biodiversity and nature loss strengthening the company's position as a sustainability leader in the sector; and improved stakeholder relationships and social license to operate.
Background: Smurfit WestRock is one of the world’s largest manufacturers of paper-based packaging products. With operations across forestry, paper, and packaging, the company has significant exposure to nature-related risks, including deforestation, biodiversity loss, and water use. In 2023, it was named as one of the 100 companies targeted under Nature Action 100 (NA100)—a global investor initiative focused on driving corporate action on nature and biodiversity loss.
Activity: WHEB acted as lead investor in this collaborative engagement. In this role, we coordinated and lead a group call with the company and later wrote a letter formalising our expectations and objectives for the company under the initiative.
Outcomes: M3 – company develops or commits to developing an appropriate policy or strategy to manage the issue
There is no progress yet on the formal objectives outlined in the letter sent in Q1 2025.
However, Smurfit WestRock remains highly engaged and motivated to work with investors on sustainability issues. In our recent call with the company, executives reaffirmed the company's strong commitment to tackling key challenges such as biodiversity and nature loss.
For example, it plans to adopt the Taskforce on Nature-related Financial Disclosures (TNFD) for FY 2026. Preparations for CSRD reporting will feed into this. The company is also currently solidifying the post-merger strategy for managing biodiversity and water impacts.
It is worth reiterating that Smurfit’s biodiversity reporting has already improved in recent years. For instance, it now discloses species data in its Colombia timberlands.
We look forward to continuing this dialogue with Smurfit in the coming months and are optimistic about it’s commitment and ability to make progress against objectives.
Steris - Ethlyne Oxide
WHEB’s objective: Limiting material negative social or environmental impacts
Company Objective: Steris to phase out the use of Ethylene Oxide (EtO) from its product portfolio
Desired outcome: Successful development of alternative technology to safely and effectively mass sterilise heat sensitive medical devices. Removing the reliance on ethylene oxide entirely.
Background: Steris uses EtO for the mass sterilisation of medical devices sensitive to heat and moisture. Chronic exposure to EtO can lead to health impacts including damage to the central nervous system and brain and an increased risk of cancer. US Regulators are implementing measures to limit emissions by more than 90% to reduce health impacts1. This creates an operational and legal risk to companies like Steris and its competitors and creates the need to expand lower-emission sterilisation alternatives. For example, in 2024, Steris was named in an EtO litigation case on claims for personal injury in the local area of a sterilisation plant.
Activity: On news of the lawsuit, WHEB initially downgraded the funds’ position in Steris. We then engaged with the company’s Investor Relations to evaluate its risk mitigation strategy for EtO-related litigation.
Engagement outcome:
M4 - company provides evidence that the issue is being managed in line with the policy or strategy, demonstrating concerns have been addressed
Steris is ahead of the curve on EtO compliance and had anticipated the EPA’s April 2024 regulatory changes. While the company stands to gain from smaller competitors exiting the market, it is not increasing its EtO capacity and remains selective in choosing customers.
Steris is aiming to reduce its reliance on EtO in its product portfolio, however a disconnect persists between the EPA’s stricter emissions limits and the FDA’s sterilisation requirements. Despite this tension, effective sterilisation of medical devices is essential and currently, there are no viable alternatives to EtO currently in development.
A related lawsuit was resolved in Q1 2025. Meanwhile, the Trump administration is pursuing a delay or weakening of EPA enforcement, creating both potential upside and ongoing regulatory uncertainty.
We have since upgraded our position on Steris.
1 As of March 2025, the Trump adminstration is now considering a two-year complaince exemption as part of it’s deregulatory agenda https://www.medtechdive.com/news/epa-emissions-standards-eto-medical-device-sterilizers/742435/
Novo Nordisk - Customer Health and Safety
WHEB’s Objective: Limiting material negative social or environmental impacts
Company Objective: Address off-label GLP-1 use, specifically for cosmetic purposes
Desired Outcome: Ensure Novo Nordisk understands its ability to manage the off-label cosmetic use of GLP-1s, safeguard patient safety, and maintain regulatory compliance and protect the company’s reputation.
Background: In 2021, Novo Nordisk launched Wegovy, a revolutionary weight-loss drug based on a specific GLP-1 (Glucagon-Like Peptide-1) hormone called semaglutide. Derived from the gut, semaglutide sends satiety signals to the brain, whilst stimulating the secretion of insulin to lower blood sugar levels. Whilst other GLP-1s are available, Wegovy has been applauded for its superior effectiveness in treating obesity, as well as the numerous related co-morbidities1 .
There is no question that the proper use of these drugs, for those with obesity or related health conditions such as diabetes, can significantly enhance health and extend lifespan when used as part of a comprehensive treatment plan. However, concerns have been raised about the impacts of “off-label use” of GLP-1s, often by non-obese individuals seeking cosmetic weight loss. This can result in shortages, impacting affordability and exposes users to potentially serious adverse side effects unnecessarily.
The implications of whether pharmaceutical companies can or should be held responsible for the potentially serious social risks associated with GLP-1s is a serious matter for their investors.
Activity: In late 2024, WHEB raised concerns with Novo Nordisk’s IR regarding the social risks of off-label GLP-1 use. The goal was to understand the company’s approach to mitigating these risks.
Engagement outcome:
M2 - company shares or agrees to disclose information on the issue
Novo Nordisk has demonstrated a proactive and responsible approach to managing potential ESG risks associated with its GLP-1 medications. The company provides robust data and prioritises educating healthcare practitioners to ensure prescriptions align with approved labelling. For example:
- Educating healthcare professionals to ensure proper prescription.
- Preventing misuse through clear communication with healthcare providers.
- Adhering to regulatory standards in advertising and marketing.
- Transparency around common side effects and the long-term safety of GLP-1s.
This comprehensive approach underscores Novo Nordisk’s commitment to responsible marketing, patient safety, and regulatory compliance, ensuring these transformative medications are used appropriately to address significant global health challenges. We nonetheless continue to monitor Novo Nordisk’s approach to this issue as off-label use of GLP-1s remains an area of concern.
Schneider Electric - Carbon - Net Zero Target/Strategy
WHEB’s Objective: Limiting material negative social or environmental impacts
Company Objective: For Schneider Electric to accelerate and enhance the positive impact of its net zero strategy. Specifically, we sought publication of a comprehensive, Paris-aligned strategy to reduce absolute Scope 1–3 GHG emissions across the business.
Desired Outcome: Improved disclosure and target setting in line with Paris Agreement as a precursor to absolute Scope 1–3 GHG emissions (tCO₂e) reductions.
Background: Schneider Electric has been included in the Net Zero Engagement Initiative (NZEI1 due to its material operational and value chain emissions, and its important role in enabling low-carbon transitions across industry. The company put a transition plan to vote in 2023, receiving near-unanimous shareholder approval. With its current strategy covering 2021–2025, the engagement group sought to influence the development of the next phase of the company’s climate strategy (2026–2030), encouraging stronger ambition, transparency, and delivery mechanisms.
Engagement Activity: WHEB has been working with the NZEI investor group. Having written to the company multiple times we are planning a meeting in 2025 to influence the next phase of Schneider’s climate strategy.
Engagement Outcome:
M4 - company provides evidence that the issue is being managed in line with the policy or strategy, demonstrating concerns have been addressed
Schneider Electric has published a strengthened, Paris-aligned net zero strategy with clear measures to reduce absolute Scope 1–3 GHG emissions. The strategy includes interim targets, implementation mechanisms, and transparency on decarbonisation levers. The company’s efforts are now better aligned with investor expectations and global climate goals, enhancing its credibility and positive impact.
MSA Safety - Hazardous chemicals
Objective
Phase-out hazardous PFAS chemicals from manufactured firefighter turnout gear
Background
Per and polyfluoroalkyl substances, also known as PFAS, are highly stable man-made molecules. Their ability to resist breaking down can make products highly resistant to water, grease and stains. PFAS have therefore been useful in a range of applications including helping firefighter turnout gear meet regulatory safety requirements. However, a growing understanding of their impacts means that the same properties that make them useful are also creating a planetary scale health risk. Without the ability to biodegrade, PFAS are accumulating in the environment and in the tissues of living organisms. From there, evidence suggests their presence can lead to cancers, autoimmune disorders, male and female infertility, obesity and diabetes1,2.
Though not a manufacturer of PFAS chemicals themselves, MSA Safety assembles turnout gear that has only been able to meet regulatory safety requirements thanks to the water and oil repelling properties of PFAS. However, in light of growing awareness of the negative impacts associated with PFAS, alternative technologies and regulatory standards are evolving to limit the need for these chemicals.
We have therefore been engaging MSA Safety to encourage them to commit to a time-bound phase-out of the chemicals. To date, the company has cited a reliance on supplier R&D as the primary obstacle to this. It had however, been working with the International Association of Firefighters to support the PFAS Alternatives Act, which would secure federal funding to support innovation.
Actions
Following announcements that the final layer of protective clothing is now available without PFAS chemicals and has recently been certified to national standards in North America3, WHEB requested a call with MSA Safety to understand its position on phase-out.
Progress/outcome
M3: Company develops or commits to develop an appropriate method or strategy to manage the issue
Though certified alternative components are now available, each of MSA’s new PFAS-free products will still need to undergo certification before being brought to market. Given the high-profile nature of the chemicals, the company expects the bar to be high and it has therefore been somewhat reserved in its marketing so far. Still, the company was confident it could bring PFAS- free products to market in early 2025.
We will continue to push MSA Safety for a time-bound commitment to total phase-out. However, we also believe the company is making meaningful progress towards this being a reality as evidenced by its work to bring PFAS-free alternatives to market as quickly is as reasonably possible.
1 https://www.sciencedirect.com/science/article/pii/S0160412019305380#bb0005
2 https://www.nature.com/articles/s41370-018-0094-1
3 https://news.bloomberglaw.com/environment-and-energy/firefighting-gear-without-pfas-heads-to-north-american-cities?Fds-Load-Behavior=force-external
Infineon Technologies - NZC targets
Objective
The overall objective is for Infineon to achieve Net Zero Carbon (NZC) emissions across Scopes 1, 2 & 3 by 2050 at the latest. The interim objective is for the company to set targets validated by the Science Based Targets initiative (SBTi).
Background
Infineon is one of the WHEB strategy's top 10 highest emitters by financed (Scope 1 & 2) emissions. When prioritising companies for engagement to meet our NZC commitments, we typically target the highest emitters as they represent the largest opportunities for significant real-world emissions reductions in the portfolio.
A key step along the way to achieving NZC commitments is to set SBTi validated targets, and WHEB has therefore committed to ensuring that 100% of portfolio companies have set such targets by 2030. Through engagement, we have made good progress towards this goal so far, with 82% of financed emissions now being covered by SBTi validated targets. However, Infineon remains a laggard in the portfolio as it has yet to have its targets validated in this way. It is therefore a priority for our engagement on NZC.
Infineon has made progress against its 2030 carbon neutrality target, reducing CO2e emissions by over 50% compared to its 2019 base year.1 However, this target does not include the company’s sizeable scope 3 emissions and is therefore not Paris Aligned. Moreover, carbon neutrality targets typically do not adhere to best practice guidance on the use of offsets, which under the SBTi are capped at 10%.
More promisingly in December 2023 Infineon committed to setting a SBTi validated NZC target. We are therefore keen to see progress on this as a priority.
Actions
In 2024, our engagement efforts with Infineon on carbon emission reductions included writing to congratulate the company on progress made in reducing Scope 1 & 2 emissions whilst also reemphasising the importance of setting a SBTi validated target.
Most recently, in Q3, we had a call with Infineon's' Investor Relations to discuss progress in setting a SBTi validated target, as well as any challenges it is experiencing and what work is being done or planned to overcome these challenges.
Progress/Outcomes
M3: During the call, we discussed how Infineon is committed to reducing its carbon emissions, but progress on certain fronts has been slower than anticipated. While the company has pledged to have its targets validated by SBTi , it has yet to provide a clear timeline for when this will be done, even though over six months have passed since its initial commitment. This delay has been somewhat disappointing, and further follow-ups are needed to ensure progress on this front.
Recently, Infineon has prioritised engaging with its suppliers to enhance sustainability within its supply chain. However, it has faced challenges, particularly in emerging markets where access to renewable energy is more limited. This has impacted the company’s ability to fully integrate green energy solutions across all its global operations.
Regarding carbon offsets, Infineon has emphasised that it aims to minimize reliance on offsets by reducing residual emissions as much as possible. The company acknowledges the complexity of addressing emissions from perfluorinated alkyl (PFA) gases, which are currently destroyed using thermal degradation using natural gas, leading to additional emissions. Infineon is still exploring solutions to this challenge, as it seeks to reduce these emissions without creating further environmental impact.
Overall, Infineon's carbon neutrality strategy is comprehensive, blending internal carbon pricing, energy efficiency initiatives, and employee engagement. Leadership incentives are tied to carbon reduction and diversity targets, ensuring that these priorities remain central to the company's broader business strategy. However, challenges like renewable energy access in some regions and the handling of PFA gases highlight areas where more progress is needed still.
Daikin - Product impact
Objective
For Daikin to exit from its business supplying weapons containing white phosphorus.
Background
We sold our position in Daikin in the Resource Efficiency theme in Q4 2023.
Daikin is a leading provider of high-quality, energy-efficient heating, ventilation and air conditioning (HVAC) solutions for the residential, commercial, and industrial sectors. The company has a long track record of profitable growth and developing innovative new products. Our investment thesis was that its energy-efficient HVAC solutions would drive market share gains over time.
We learned that the company was involved in the production of white phosphorus weapons and therefore divested. Weapons containing white phosphorus are widely considered to be controversial because of their incendiary characteristics.
Having consulted with WHEB’s independent Investment Advisory Committee, we decided to include white phosphorus in our definition of banned and controversial weapons where we apply a 0% revenue threshold1.
Actions
WHEB engaged Daikin on this matter with the aim of having the company exit the business supplying white phosphorus containing weapons.
In our communication, we outlined both WHEB’s own concerns, as well as those of our investors. We also explained that any company with any activity involving armaments and white phosphorus is a prohibited investment and that we would ultimately sell our position in Daikin if it remained committed to this activity.
Unfortunately, we were unable to get any reassurance that the company was thinking about exiting the business so we sold our shares in Daikin in Q4 2023 and disqualified it from our investment universe.
Progress/Outcomes
M4 – It was recently announced that Daikin has decided to exit the production and sale of artillery shells containing white phosphorus that it supplies to Japan’s Ministry of Defence. While fulfilling existing orders through to the end of 2025, Daikin has stopped accepting new orders as of this year.
Although Daikin still faces several challenges, including an inventory surplus, rising global competition, and recent management disruption, this move signals a commitment to ESG priorities and addresses ESG concerns raised by WHEB and other stakeholders.
1 https://www.whebgroup.com/assets/files/uploads/20240110-ethical-outcomes-final.pdf
Siemens Healthineers - Product impact
Objective
For Siemens Healthineers to publish data that helps to strengthen investors’ understanding of the positive impacts enabled through its products and services.
Background
We continually seek to further strengthen our understanding of the positive impact associated with the products and services sold by our investee companies. Additional insights allow us to build a stronger investment case and ‘impact story’ for each of our stocks. WHEB encourages investee companies to improve how they report on the positive sustainability impacts of their products and services. This helps other investors recognise these companies as having a strong impact, making it easier for them to direct capital toward these businesses.
Actions
The Investor Relations representative for Siemens Healthineers visited our offices. This gave us the opportunity to ask him for further information and data with regards to the positive impact of the company's Varian segment on patient outcomes.
Progress/Outcomes
M2
Siemen’s Healthineers shared information regarding Varian's latest innovation, HyperSight. This technology offers significantly higher resolution imaging and drastically reduces image acquisition time from 60 seconds to just 6 seconds. This enables better visualization and faster workflow. Importantly, HyperSight allows real-time adaptation of treatment if the tumour or surrounding organs have shifted, avoiding delays and ensuring more effective, personalized therapy. This innovation improves clinical outcomes by offering superior accuracy and flexibility in treatment, benefiting patient care.