Sustainable and responsible value creation

Our approach to responsible investment

A.P. Moller Capital focuses on sustainable value creation by building businesses that seek to generate a financial outcome and support society through economic and social development.

We use our ownership position to actively ensure portfolio companies work towards implementing high environmental, social and governance (“ESG”) standards. We believe that this mitigates investment risk, results in companies with better governance, more social focus, lower environmental impact and, ultimately, higher value.

We want our infrastructure investments to reduce the cost of doing business, unlock economic potential and support jobs. At the same time, we want to be an active participant in the low carbon transition and reduce greenhouse gas emissions, without compromising returns. We are members of the Institutional Investors Group on Climate Change.

Key ESG commitments

Our Responsible Investment Framework is based on the principles of the UN Global Compact and the UN Principles for Responsible Investment to which A.P. Moller Capital is a signatory.

Related to sustainability, we follow good international industry practice. This includes the IFC Performance Standards on Environmental and Social Sustainability including the World Bank Group Environmental, Health and Safety Guidelines, the OECD Guidelines for Multinational Enterprises and the UN Guiding Principles on Business and Human Rights.

Related to good governance practice, we have developed internal policies and procedures in relation to anti-bribery and anti-corruption in compliance with the US, UK and Danish regulations, Anti-Money Laundering (“AML”) in compliance with the EU AML Directive, responsible tax practices, and guidelines for company boards.

We integrate ESG throughout the investment cycle

Responsible investing is a central element of our investment strategy and is integrated throughout the investment cycle, from origination to exit. We incorporate ESG risks into our investment analysis and decision making. Regardless of sector or jurisdiction, we pledge to be an ethical partner and apply the same high ESG standards to our investments.

We require our portfolio companies to assign responsibilities to effectively identify, manage and monitor ESG risks, work with responsible business counterparties, and engage transparently and proactively with stakeholders. We closely follow the ESG performance of portfolio companies and provide support, when necessary.

Environmental and Social Management System

A.P. Moller Capital operates under an ethical policy that requires Environmental, Social and Governance (ESG) considerations to be included in the investment process. The policy is based on the main principles of the UN Global Compact, the United Nations Principles for Responsible Investment, the IFC Performance Standards on Environmental and Social Sustainability, and the EU Sustainable Finance Disclosure Regulation. It references and centralizes all ESG-related procedures including, but not limited to, the ESG Handbook, which is an operational document developed for the investment team that outlines A.P. Moller Capital’s internal process with regards to environmental and social due diligence, risk assessment, environmental and social categorization, and subsequent monitoring.

The purpose of the ethical policy is to protect people and the environment, minimize negative environmental and social impacts, prioritize safe and healthy working conditions and the fair treatment of employees, and ensure that all A.P. Moller Capital’s investments undergo a rigorous ESDD process. A.P. Moller Capital’s ethical policy outlines the requirement to refrain from engaging with partners that do not adhere to the specified ESG principles and establishes A.P. Moller Capital’s internal Exclusion List, which is to be amended for EMIF II.

iconExclusion list

The integration of ESG considerations into the A.P. Moller Capital investment process


Screening: At the early stage in the investment process, it is determined whether the potential investment will be able to meet A.P. Moller Capital ESG requirements. All potential investments are screened against A.P. Moller Capital’s sustainable investment framework to determine whether they meet our Art. 9 commitments. All investments are also screened against our exclusion list and assigned an E&S risk category, which provides an indication of the level of E&S risks associated with the investment. The E&S risk category, which is subsequently confirmed during the due diligence process, also provides A.P. Moller Capital with information on the extent of due diligence that is required. To comply with regulations covering anti-money laundering, anti-bribery and anti-corruption measures, sanctions, financial crime and terrorism financing, initial integrity screenings are carried out to identify, as early as possible, any illegal practice by counterparties with whom A.P. Moller Capital will refrain from doing business. The initial screening identifies high risk issues that need to be covered during in-depth Due Diligence (see below).

Due Diligence: After the initial screening, A.P. Moller Capital engages a qualified third party (external E&S consultant) to conduct an ESDD on the investment. The findings of the due diligence process are considered during the Investment Committee, including the extent of any non-alignment with A.P. Moller Capital’s ESG requirements, as well as alignment with the IFC PS. The results of the ESDD are also discussed during the Risk and ESG Committee, which provides its comments prior to the Investment Committee. An environmental and social action plan is developed for situations where an investment is not aligned with A.P. Moller Capital’s ESG requirements. The plan specifies the action to be taken towards alignment and the deadline by which gaps in this regard will need to be closed. In addition to the ESDD, an Integrity Due Diligence (IDD) is carried out to identify and assess areas of concern in relation to the background of potential investments, including key personnel, as well as any other relationships and activities that could cause reputational or commercial risk to A.P. Moller Capital. Any red flags identified during the initial integrity screening are covered during the IDD.

Investment Agreement: Each investment has an associated shareholder agreement (SHA) that is used to obtain a commitment from the portfolio company on key shareholder matters, including ESG. The SHA requires that our portfolio companies align with APMC’s Ethical Policy. Appended to the SHA is the ESAP, which includes the areas for improvement highlighted during the due diligence process.

Portfolio Company Management: To ensure portfolio companies meet the requirements of A.P. Moller Capital’s ESG principles throughout the entire period of the investment, all company policies are to be aligned with the A.P. Moller Capital Portfolio Company Governance Manual. In addition, A.P. Moller Capital is committed to the portfolio company meeting IFC PS 1, and certified Environmental and Occupational Health and Safety systems. In collaboration with the investment and ESG teams, the A.P. Moller Capital nominated board representative should ensure ESG actions are appropriately implemented and monitored. A.P. Moller Capital tracks the ESG performance of all its portfolio companies and tracks numerous fund level and regulatory ESG KPIs.

Exit: A.P. Moller Capital conducts an integrity check on potential buyers to ensure the protection of its reputation. During the exit process, information is collected on the positive impact achieved, completion of ESAP, ESG improvements and other documentation (e.g., ESIA, permits, regular reporting).

Sustainability-related disclosures

In compliance with the EU Sustainable Finance Disclosures Regulation (2019/2088) we integrate sustainability risks in the investment decision-making process, and consider principal adverse impacts on our investment decisions. More information can be found in the Responsible Investment Framework, which also describes how sustainability risks are integrated in the remuneration policy.

iconDownload our ESG Report 2022

iconDownload our Responsible Investment Framework

iconDownload Africa Infrastructure Fund I website disclosure

iconDownload Africa Infrastructure Fund I SFDR Annex 4 disclosure

iconDownload Statement on principle adverse impacts of investment decisions on sustainability factors

Where to find us


A.P. Møller Capital P/S
Lyngby Hovedgade 85,
Kongens Lyngby, Denmark,


A.P. Møller Capital P/S (DIFC Branch)
Al Fattan Currency House 2-1502/1503
DIFC Dubai
United Arab Emirates


A.P. Moller Capital (Singapore) Pte. Ltd.
Marina Bay Financial Center
Tower 1, 14th Floor

A.P. Møller Capital P/S is governed and regulated by the Danish Financial Supervisory Authority as an Alternative Investment Fund Manager. A.P. Møller Capital P/S (DIFC Branch) is regulated by the Dubai Financial Services Authority to provide advice and arrange deals in investments, to support the headquarter in Denmark. A.P. Moller Capital (Singapore) Pte. Ltd., a fully owned subsidiary of A.P. Møller Capital P/S, is exempt from licensing to provide advice on investments to its shareholder.

How to contact us


Melanie Beck
T: +971 55 588 6592


Peter Wernberg Nielsen
T: +45 20 44 93 77


Kelly Lynch
T: +45 31 42 94 99

Complaints & Whistle-blowing

A.P. Moller Capital has appointed the Head of Compliance as Complaints Manager.


A.P. Moller Capital has implemented a whistle-blower system and encourages you to help fight corruption, business crime and other unacceptable business conduct.