Statement of the responsible management policy for the credit and investment portfolio




The objective of the responsible management policy for the credit and investment portfolio is to explain the commitments, strategy and governance for integrating Environmental, Social and Governance (ESG) criteria into the responsible management of the Bank’s credit and investment portfolio.


This policy applies to all loans granted by Spuerkeess to its clients included in the national portfolio and bond investments included in the Bank’s international portfolio.


This policy does not cover the Bank’s subsidiaries and equity investments in companies located in the Grand Duchy or abroad. Equity investments held by clients are also outside of the scope of this policy. The Bank’s investment policy for asset management and client accounts is detailed in a separate investment policy.


Spuerkeess’ policy aims to align its business strategy with national and international sustainability and ESG goals, as defined by the Paris Climate Agreement, the Sustainable Development Goals (SDGs) and the United Nations Global Compact. The Bank is also committed by signing the Principles for a Responsible Bank (PRB) and by joining the Net-Zero Banking Alliance (NZBA), with the aim of facilitating the transition to a sustainable economy in Luxembourg. This policy contributes to the Sustainable Development Goals of the United Nations 2030 Agenda, in particular Goal 8 on decent work and economic growth, 12 on responsible consumption and production, and 17 on partnerships to achieve the Goals.


Given the transversal nature of this policy, Spuerkeess opted for a collaborative governance.

  • At the strategic level, the Strategic & Sustainability Office develops, in collaboration with the Loan & Credit Management department and with the Global Markets department, the ESG strategy and the associated objectives.
  • At the decision-making level, the Extended Management validates and the Board of Directors approves the policy, strategy and their implementation within Spuerkeess.
  • At the operational level, the Bank’s various departments are responsible for implementing and complying with this policy.

This policy is implemented in the Bank’s processes.


The 3 guiding principles are as follows:

  • We are a socially responsible lender: Spuerkeess is committed to acting as a “socially responsible lender” in accordance with our social mission as defined by Art. 5 of the Organic Law of 24 March 1989. The Bank undertakes to ensure that this responsibility is demonstrated throughout all activities.
  • We incorporate ESG risks into the management of our loans and investments: Spuerkeess applies a top-down approach to monitor and mitigate transition risks and a bottom-up approach by incorporating indicators and criteria into its credit policies and procedures. The overall objectives are defined in the Risk Appetite Framework and rolled out at each counterparty level with an assessment based on various criteria and thresholds. These criteria and thresholds may vary from sector to sector and from portfolio to portfolio.
  • We develop our carbon-neutral transition plan: The Bank is committed to fight climate change by joining initiatives such as the United Nations Principles for Responsible Banking, the Partnership for Carbon Accounting Financials and the Net Zero Banking Alliance. In addition, the Bank’s business strategy is to gradually align with the 1.5°C climate scenario of the Paris Climate Agreement, with the requirements of the Sustainable Finance Action Plan adopted by the European Union and the Luxembourg National Energy and Climate Plan. Spuerkeess is also committed to promoting sustainability by supporting the financing of sustainable projects nationally and increasing its portfolio of international companies that have committed to reducing their financial and physical carbon intensities.
    • National portfolio Spuerkeess actively finances sustainable projects for large companies, SMEs and green innovations, including renewable energy. In collaboration with our service providers, a comprehensive solution is offered to corporate clients to facilitate the preparation of their sustainability reports, thus promoting transparent and responsible management of their activities. An exposure limit is established for the companies most vulnerable to transition risks. In addition, the residential mortgage portfolio now incorporates measures to promote energy efficiency and sustainability.
    • ​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​International level Internationally, Spuerkeess adjusts its investment portfolio in favour of companies committed to reducing their carbon emissions. It also invests in special purpose debt securities in line with EU taxonomy’s objectives. An exclusion policy is in place for controversial activities and ESG controversies. To monitor and mitigate transition risks, a number of indicators have been integrated into the risk appetite framework, including the alignment with green bond standards, financial and physical carbon intensities, and the identification of climate sensitive sectors.


The responsible management policy for the credit and investment portfolio, and thus the resulting statement, are reviewed at least annually or when required by the relevant practices and/or regulatory aspects.