The Accident Compensation Corporation says it has not breached the Cluster Munitions Prohibition Act 2009 and it has not invested money in the development or production of cluster munitions.

A statement from ACC says it has not invested directly in any company on our investment exclusion list, nor have we invested through any collective investment vehicle with the intention or knowledge that money would be invested in any company on our investment exclusion list.

The statement provides information on ACC's involvement with a collective investment vehicle which had purchased shares in Lockheed Martin among other companies. Lockheed Martin is on the ACC ethicial exclusion list.

ACC says it has recently strengthened its ethical investment policy governing the processes for investing via collective investment vehicles.

"We are confident the recent change in the ethical investment policy addresses our responsibilities."

The ACC ethical investment policy is difficult to locate on the corporation's website. However, its 2014/15 Service Agreement makes the following statement:

"We have an ethical investment policy that requires our investment activities to be conducted in an ethical manner that avoids prejudice to New Zealand's reputation as a responsible member of the world community. We apply ethical principles that, in our judgement, are widely held by the New Zealand public. The spirit of New Zealand laws is used as a guide to reflect the ethical views of the New Zealand public, together with the values and principles set out in the United Nations Global Compact and the United Nations Principles for Responsible Investment (UN PRI). 

"The ethical investment policy sets out a framework that: 

• requires engagement with companies that have serious environmental, social or governance issues in order to modify their corporate behaviour and improve their performance in relation to ethical issues. This is undertaken directly with the companies or in collaboration with other Crown financial institutions, other investors or the UN PRI Engagement Clearinghouse 
• excludes from our investment portfolio companies that undertake activities that are repugnant to the laws of New Zealand and exhibit corporate behaviour that seriously breaches ethical/responsible investment standards. These include tobacco companies and those involved with the development and/or production of anti-personnel mines, cluster munitions and nuclear explosive devices 
• encourages our fund managers to cast proxy votes in a manner that is consistent with the principles of good corporate governance and the ethical investment policy."

The ACC information on investments states that its ethical investment policy requires it to consider the ethical implications of its investments alongside operational risk.