Ethical investments review

Background 

In its proceedings on 28 May 2024, Congregation raised a series of questions around the University’s investment policies relating to armaments. These were published, alongside the responses from Council, in the Gazette. The University policy at the time prohibited both direct investment in companies manufacturing arms that are illegal under UK law (introduced in 2010) and investment in funds which invest primarily in such companies. The policy also included restrictions relating to the approach to sustainability and ethical investment. Further information on how the University manages its investments are found in the notes below.

Council subsequently commissioned the Ethical Investment Representations Review Subcommittee (EIRRS) to lead a University-wide review of the restrictions on investments in entities related to armaments, and to consider the continued appropriateness of the restrictions or whether they should be extended (see review terms of reference).  

Review process 

EIRRS is a subcommittee of the University’s Investment Committee and undertook the Review in three phases: (i) research, (ii) engagement, and (iii) debate and emergence of the recommendations. A website was developed to outline the steps of the review and provide updates on progress.  The review involved extensive research, broad engagement with staff and students, and benchmarking against other institutions.  

EIRRS sought to engage all University members through a dedicated website, presentations, and webinars, which invited written submissions. This included a student consultation undertaken by the Students’ Union, which engaged widely with students through webinars, briefings with key student groups, and surveys.  

Over 500 student and staff members were engaged in the process, with 81 submissions received by the University. A further 86 were received by the Students’ Union, and the resulting submission to the review reflected the range of student feedback.  

The review confirmed that, as a result of fund management policies and principles, the University has no direct or indirect investment exposure to any of the companies on the existing armaments restricted list.  

Outcomes 

In July 2025, EIRRS reported its findings to the Investment Committee (IC). The IC then evaluated EIRRS’ recommendations and advised Council, resulting in an update to the Investment Policy Statement and a commitment to further evolution of communications in relation to the University’s investments.  

Summary of recommendations and Council decisions 

The Review’s recommendations cover five areas of activity in relation to the University’s investment policy: 

• Recommendation 1: Expanding the list of prohibitions 
• Recommendation 2: Applying the updated prohibition list to direct investments 
• Recommendation 3: Applying the updated prohibition list to indirect investments 
• Recommendation 4: Oversight and membership of scrutiny committees 
• Recommendation 5: Disclosure and communication 

Recommendation 1 (Expanding the list of prohibitions): The prohibition that the University should not invest in companies manufacturing arms that are illegal under UK law should remain the foundation of the investment policy. The Committee notes that since the policy was set in 2010 the UK has now ratified Protocol V of the “UN Convention on Certain Conventional Weapons (CCW)” 13 May 2024. The Committee recommends extending the prohibition to weapons which are illegal under the CCW, and any other relevant international treaties to which the UK is a signatory, and that the Investment Committee should explore implications and feasibility for Council. This definition is referred to in subsequent recommendations as the “updated restriction list”.   

Weapon types that are currently banned under the University’s restriction list are: 

• Cluster munitions 
• Anti-personnel landmines 

Weapon types that will be added to the restriction list are: 

• Chemical and biological weapons 
• Blinding laser weapons 
• Non-detectable fragments 
• Incendiary weapons (white phosphorus) 

Fuller information about the relevant international treaties relevant to banning armaments and weapons follows in the notes below. 

Decision: Council endorsed this recommendation noting that it should also apply automatically to provisions under relevant international armament treaties which the UK signs in the future.  

Recommendation 2 (Direct investments): The existing prohibition should continue with the exception of the adoption of the updated restriction list: there should be a prohibition on direct investment in companies manufacturing arms classified as prohibited under the updated restriction list, as well as investment in funds which invest primarily in such companies. 

Decision: Council endorsed this recommendation.   

Recommendation 3 (Indirect investments): In relation to the University’s indirectly held portfolio, that Investment Committee and Council consider adopting (i) a prohibition on the University initiating or renewing an investment in a fund where it is known or reasonably expected that the fund holds or will hold material investments in companies caught by the updated restriction list, (ii) a requirement for Investment Committee to enact appropriate remediation if and when indirect holdings breach an agreed threshold, where appropriate remediation can be achieved at reasonable cost, and (iii) an enhancement to the procedures such that any remedial actions should also be reported to Council, in addition to the Investment Committee. 

Decision: Further to advice from the Investment Committee, Council noted that, to date, best endeavours have been used to ensure the University has no direct and indirect investment exposure to any of the companies on the existing armaments restricted list. Following its review, Investment Committee had also confirmed that there was no exposure to the additional companies prohibited under the Updated Restriction List. Council noted the challenges of being formally bound by a commitment to zero Restricted List exposure, and agreed a ‘best endeavours’ approach to avoid indirect University exposure to funds investing in companies on the armaments Updated Restricted List, with a limit of a value equivalent to 1% or more of the University’s total investments.  

Recommendation 4 (Oversight and membership of scrutiny committees):  

(i) There should be a formal annual joint meeting between EIRRS and CRDRF to facilitate the exchange of perspectives on current and emerging ethical issues,  
(ii) that Investment Committee approves and recommends to Council that EIRRS’s membership should include representatives from each of the four academic divisions and GLAM, plus a Head of House, to better reflect the diversity of views within the University, and  
(iii) that Investment Committee approves and recommends to Council that, where additional expertise is required, EIRRS should have the ability to co-opt members, or ask University members to join their deliberations on specific representations on a time-limited basis, such as human rights, or gambling addiction. 

Decision: Council did not take forward the recommendation for an annual joint meeting, noting the existing link between EIRRS and CRDRF, which have joint membership. While EIRRS’s role is to develop investment policy, CRDRF deals with specific companies and individuals, therefore the confidentiality required by CRDRF prohibits information-sharing.

Council did not take forward the recommendation to add additional members to EIRRS or the Chair of Conference of Colleges as an ex-officio member of EIRRS, noting that colleges have independent investment strategies, and that under EIRRS’s current governance it already has flexibility to call on a wide range of experts as required, including representation from Conference.  

Recommendation 5 (Disclosure and communication):   
(i) that Investment Committee works with OUEM and the University to enhance disclosure regarding the University’s investments, their management (including the restrictions outlined in the University’s Investment Policy Statement) and the role that the endowment plays in supporting the University’s work, and  
(ii) EIRRS will seek to raise awareness of its role, and the possibility for University members to submit representations. 

Decision: Council endorsed this recommendation. 

The full report from EIRRS can found here: 1. EIRRS Review 2025_06_19_FINAL.pdf

Notes 

The University has a variety of investments as outlined in its financial statements. Council is the trustee of the University’s investments. The majority of these are overseen by the Investment Committee and managed by Oxford University Endowment Management (OUem). OUem is a commercial operating subsidiary of the University, and it manages investments for the University and 45 other investors in the Oxford Endowment Fund (OEF), a regulated investment fund for long term endowments. How OUem manages the OEF, including its approach to sustainability is included on www.ouem.co.uk.  

Further information on the University’s investments can be found: University of Oxford’s endowment and investments | University of Oxford 

Further information on EIRRS is found: https://governance.admin.ox.ac.uk/ethical-investment-representations-review-subcommittee  

International arms treaties and conventions  

International treaties relevant to banning armaments and weapons are complex; the following information is based on publicly available sources.