Solutions  /  Pension fund evidence report  /  Commitments

For pension funds, master trusts and consultants

What the scheme promised, and whether it can be tested.

A scheme’s commitments sit in two layers — the trustee’s statement of investment principles and the funds’ own policies — and most are worded so that nothing can be tested against them. This report lists every published commitment across both layers, quoted with its page, states the share of the equity allocation each binds, marks which ones the holdings can actually be tested against, and sets the scheme beside its peers. The holdings test itself is on the evidence report.

Basis
Fund’s own holdings schedules
Holdings as at
28 Feb 2026
Evidence as at
31 Aug 2026
Output
Report, CSV, API
Built for
Pension funds · Master trusts · Consultants

A commitments report, on this page

Aegon Workplace Default: every commitment it has published, which layer made it, what it binds, and whether it can be tested. Open any row for the wording and its source.

Subscribe →
← back to the holdings report
Commitments report
Aegon Workplace Default — can what it promised be tested?
10 published commitments across two layers, read from the scheme’s own documents and its underlying funds’ methodologies. This report examines the wording. It needs no holdings and does not change when the fund rebalances.
10published commitments, two layers
4not testable as written
1need data this report does not carry
4tested against holdings
Layer 1 · the trustee’s own statement of investment principles
5 commitments
StandardWhat the scheme wroteThreshold Result
▸ Other“The trustees have committed to net-zero carbon emissions of the default solution by 2050.”
default solution · p.5
net zero by 2050NO INTERIM MEASURE
Mechanism
target
Scope as written
default solution
Threshold
net zero by 2050
Why it cannot be tested as written. An endpoint with no interim measure. There is no year in which it can pass or fail.
The wording that would fix it: Add a dated interim measure — an intensity reduction against a stated baseline, by a stated year. That can be tested annually.
▸ Controversial weapons“we are guided by our exclusions’ framework: Controversial weapons”
default fund reviews / new business · p.7
not statedNOT BINDING
Mechanism
policy guidance
Scope as written
default fund reviews / new business
Threshold
not stated
Why it cannot be tested as written. “Guided by” is a statement of approach, not a prohibition. Nothing can breach it.
The wording that would fix it: State the exclusion: “the default arrangement excludes …”.
▸ Tobacco“we are guided by our exclusions’ framework: tobacco manufacturing and retail”
default fund reviews / new business · p.7
not statedNOT BINDING
Mechanism
policy guidance
Scope as written
default fund reviews / new business
Threshold
not stated
Why it cannot be tested as written. “Guided by” is a statement of approach, not a prohibition. Nothing can breach it.
The wording that would fix it: State the exclusion: “the default arrangement excludes …”.
▸ UN Global Compact“controversies related to the UN Global Compact principles”
default fund reviews / new business · p.7
not statedNOT TESTABLE
Mechanism
policy guidance
Scope as written
default fund reviews / new business
Threshold
not stated
Why it cannot be tested as written. “Controversy” has no adjudicator, no date and no threshold. Two readers would exclude different companies.
The wording that would fix it: Replace with “an adjudicated determination by a named regulator” — a decision, on a date, with a citable source.
▸ Thermal coal“thermal coal and oil sands extraction”
default fund reviews / new business · p.7
not statedNOT YET TESTED
Waiting on: the data the rule runs on
Mechanism
policy guidance
Scope as written
default fund reviews / new business
Threshold
not stated
Layer 2 · the underlying funds inside the default
5 rules
StandardCommitmentShare of equities Result
▸ Index membership“track the performance of the FTSE Developed ESG Low Carbon Select Index”
HSBC Developed World Lower Carbon ESG Tilt Equity Index Fund · p.Objectives
31.5%NOT YET TESTED
tracks the FTSE Developed ESG Low Carbon Select Index: benchmark identity confirmed, exact ground rules not located (searched 7 Oct 2026). The similar FTSE MPF ESG Low Carbon Select rulebook covers Hong Kong retirement indices and must not be applied
Mechanism
commitment
Scope as written
HSBC Developed World Lower Carbon ESG Tilt Equity Index Fund
Threshold
index membership and weight
Not yet tested, and not forced into a test it does not ask for. tracks the FTSE Developed ESG Low Carbon Select Index: benchmark identity confirmed, exact ground rules not located (searched 7 Oct 2026). The similar FTSE MPF ESG Low Carbon Select rulebook covers Hong Kong retirement indices and must not be applied A rule outside this report’s scope is never shown as met, and never as a pass.
▸ Thermal coal“Thermal Coal Extraction-Level of Involvement Id >5%”
Five iShares ESG Screened and Optimised regional sleeves (Europe, EM, Japan, UK, US) · p.Appendix 5
47.7%TESTED, SOME HOLDINGS DISCLOSE NO FIGURE
At >5% involvement; power-generation revenue >5%: Rule: more than 5% involvement in thermal coal extraction, or more than 5% of revenue from coal-fired power generation. 0 over threshold of 2,209 issuers in scope; 9 measured on a different boundary (0.08%); 12 not disclosed (0.39%); 83 answered from existing register rows, nothing collected; 2,005 screen-negative (1,568 on Scottish Widows' / Standard Life's review of the same company; a screen, not a document); 121 candidates not collected (0.68%; register-only run). Other schemes' coal levels: Mercer >1%, Scottish Widows ≥5%, Standard Life >5%, Mercer ≥5%, Fidelity >5%, Atlas / SEI >10%, Royal London ≥60%. Holdings 28 Feb 2026 (the five iShares sleeves).
Mechanism
commitment
Scope as written
Five iShares ESG Screened and Optimised regional sleeves (Europe, EM, Japan, UK, US)
Threshold
>5% involvement; power-generation revenue >5%
What the test found. Rule: more than 5% involvement in thermal coal extraction, or more than 5% of revenue from coal-fired power generation. 0 over threshold of 2,209 issuers in scope; 9 measured on a different boundary (0.08%); 12 not disclosed (0.39%); 83 answered from existing register rows, nothing collected; 2,005 screen-negative (1,568 on Scottish Widows' / Standard Life's review of the same company; a screen, not a document); 121 candidates not collected (0.68%; register-only run). Other schemes' coal levels: Mercer >1%, Scottish Widows ≥5%, Standard Life >5%, Mercer ≥5%, Fidelity >5%, Atlas / SEI >10%, Royal London ≥60%. Holdings 28 Feb 2026 (the five iShares sleeves).
▸ Oil sands“Oil Sands Extraction-Revenue Percentage >5%”
Five iShares ESG Screened and Optimised regional sleeves (Europe, EM, Japan, UK, US) · p.Appendix 5
47.7%TESTED, SOME HOLDINGS NOT SETTLED
At >5% revenue: Rule: more than 5% of revenue from oil sands extraction. 0 over threshold of 2,209 issuers in scope; 1 measured on a different boundary (0.13%); 17 answered from existing register rows, nothing collected; 2,135 screen-negative (1,636 on Scottish Widows' / Standard Life's review of the same company; a screen, not a document); 57 candidates not collected (0.22%; register-only run). Holdings 28 Feb 2026 (the five iShares sleeves).
Mechanism
commitment
Scope as written
Five iShares ESG Screened and Optimised regional sleeves (Europe, EM, Japan, UK, US)
Threshold
>5% revenue
What the test found. Rule: more than 5% of revenue from oil sands extraction. 0 over threshold of 2,209 issuers in scope; 1 measured on a different boundary (0.13%); 17 answered from existing register rows, nothing collected; 2,135 screen-negative (1,636 on Scottish Widows' / Standard Life's review of the same company; a screen, not a document); 57 candidates not collected (0.22%; register-only run). Holdings 28 Feb 2026 (the five iShares sleeves).
▸ Tobacco“Tobacco Products Production-Level of Involvement Id >0%”
Five iShares ESG Screened and Optimised regional sleeves (Europe, EM, Japan, UK, US) · p.Appendix 5
47.7%TESTED, SOME HOLDINGS NOT SETTLED
At >0% production; other tobacco thresholds apply: Rule: any production of tobacco products (over 0%); the fund's other tobacco thresholds are not tested here. 0 over threshold of 2,209 issuers in scope; 50 answered from existing register rows, nothing collected; 2,113 screen-negative (1,599 on Scottish Widows' / Standard Life's review of the same company; a screen, not a document); 46 candidates not collected (0.38%; register-only run). Holdings 28 Feb 2026 (the five iShares sleeves).
Mechanism
commitment
Scope as written
Five iShares ESG Screened and Optimised regional sleeves (Europe, EM, Japan, UK, US)
Threshold
>0% production; other tobacco thresholds apply
What the test found. Rule: any production of tobacco products (over 0%); the fund's other tobacco thresholds are not tested here. 0 over threshold of 2,209 issuers in scope; 50 answered from existing register rows, nothing collected; 2,113 screen-negative (1,599 on Scottish Widows' / Standard Life's review of the same company; a screen, not a document); 46 candidates not collected (0.38%; register-only run). Holdings 28 Feb 2026 (the five iShares sleeves).
▸ UN Global Compact“Noncompliance with U.N. Global Compact”
Five iShares ESG Screened and Optimised regional sleeves (Europe, EM, Japan, UK, US) · p.Appendix 5
47.7%TWO MEASURES — 208 HOLDINGS CARRY A FINDING WE MAP TO IT
Mechanism
commitment
Scope as written
Five iShares ESG Screened and Optimised regional sleeves (Europe, EM, Japan, UK, US)
Threshold
non-compliance status
Not yet tested. A number, a direction and a unit. The row is waiting on UNGC issuer-status dataset and dated official index constituents. A rule outside this report’s scope is never shown as met.
A rule outside this report’s scope is never shown as met. Where a rule is quantified and binding but requires data this report does not carry, it is reported as covered in the extended report — not as a failure of the scheme, and never as a pass.
How this scheme compares
On the wording alone
A count of commitments says nothing without a weight. Share of equities bound by a published, quantified rule is the column that matters.
Scheme Excluded Adverse Own commitments CommitmentsQuantified Equities boundPosition
Atlas / SEI→—
no UNGC rule
—
no UNGC rule
commitments partially tested
Controversial weapons any stated involvement: 0 over, some holdings disclose no figure
Thermal coal >10% annual revenue: 0 over, some holdings disclose no figure
Failure of good-governance test: not yet tested
Failed good-governance test: not yet tested
62100.0%1 of 8 by equities bound
Scottish Widows→—
UNGC rule binds some sleeves only
—
UNGC rule binds some sleeves only
commitments fully tested
Controversial weapons any involvement (manufacturer): 0 over, a finding held pending decision
Tobacco > 10% of value-chain revenue: 0 over, some holdings disclose no figure
Thermal coal >= 5% of revenue from extraction: 0 over, some holdings disclose no figure
Oil sands >= 5% of revenue from tar sand extraction: 0 over, some holdings disclose no figure
159100.0%2 of 8 by equities bound
Standard Life (PUTM)→—
UNGC rule binds some sleeves only
—
UNGC rule binds some sleeves only
commitments partially tested
Controversial weapons zero tolerance: 0 over, a finding held pending decision
Tobacco > 1% of revenue (production): 0 over
Tobacco > 25% of revenue (distribution, retail and supply): 0 over, some holdings disclose no figure
Thermal coal > 5% of revenue (mining and energy production): 0 over, some holdings disclose no figure
Arctic drilling > 5% of revenue: 1 over, some holdings disclose no figure
Oil sands > 5% of revenue: 1 over
Thermal coal >=20 (waiver 20-30 with SBTi Paris-aligned targets): not yet tested
Oil sands and oil and gas >=20: not yet tested
Tobacco >=1: not yet tested
External rating: not yet tested
Norms and controversies third-party controversy flag: not yet tested
613792.7%3 of 8 by equities bound
Aegon→—
no UNGC rule
—
no UNGC rule
commitments partially tested
Thermal coal >5% involvement; power-generation revenue >5%: 0 over, some holdings disclose no figure
Oil sands >5% revenue: 0 over, some holdings disclose no figure
Tobacco >0% production; other tobacco thresholds apply: 0 over, some holdings disclose no figure
Controversial weapons: no threshold stated
Tobacco: no threshold stated
Thermal coal: no threshold stated
Index membership and weight: not yet tested
10479.2%this scheme — 4 of 8 by equities bound
Smart→—
UNGC rule binds some sleeves only
—
UNGC rule binds some sleeves only
commitments fully tested
Thermal coal >20% revenue: 0 over, some holdings disclose no figure
Oil sands >20% revenue: 0 over, some holdings disclose no figure
Controversial weapons index exclusion per methodology: 0 over, some holdings disclose no figure
6450.9%5 of 8 by equities bound
Mercer→—
UNGC rule binds some sleeves only
—
UNGC rule binds some sleeves only
commitments partially tested
Thermal coal: 15 rules, 13 tested, 0 over
Deforestation: 1 rule, 0 tested, 0 over
Index membership: 9 rules, 0 tested, 0 over
Adult entertainment: 6 rules, 6 tested, 3 over
Alcohol: 2 rules, 2 tested, 0 over
Controversial weapons: 16 rules, 11 tested, 0 over
Fossil fuels: 2 rules, 2 tested, 0 over
Oil sands: 8 rules, 8 tested, 0 over
Gambling: 2 rules, 2 tested, 0 over
Tobacco: 22 rules, 22 tested, 0 over
Civilian firearms: 21 rules, 21 tested, 0 over
Fossil-fuel power generation: 1 rule, 1 tested, 0 over
SDG impact rating: 1 rule, 0 tested, 0 over
Norms and controversies: 5 rules, 0 tested, 0 over
Arctic drilling: 2 rules, 2 tested, 0 over
1228232.1–42.1%6 of 8 by equities bound
Fidelity→—
no UNGC rule
—
no UNGC rule
commitments fully tested
Thermal coal >5% revenue: 0 over, some holdings disclose no figure
Oil sands >5% revenue: 0 over, some holdings disclose no figure
6432.0%7 of 8 by equities bound
Royal London→—
no UNGC rule
—
no UNGC rule
commitments partially tested
Controversial weapons any manufacture: 0 over, some holdings disclose no figure
Thermal coal >=60% revenue: 1 over, some holdings disclose no figure — loosest coal level in the set
Thermal coal >=2bn tonnes reserves: not yet tested
6430.6%8 of 8 by equities bound
On the bar and Adverse are different questions. A scheme asking which holdings reach our bar is asking the first; whether its own provider’s list reaches them is a question for the manager. Adverse is wider — it includes severe determinations that do not reach the bar — and a fund can sit high on it while breaching nothing. Both are shaded against their own column, never against 100%, because a column where every cell is pale distinguishes nothing.
The UN Global Compact rule, set beside adjudicated findings
208 of 1131 holdings — 20.74% of the extracted equity lines — carry a finding we map to a principle
The fund’s rule runs on its provider's data, which the scheme does not name; this figure does not. They are different measures and they disagree. Each finding is dated, sourced, and listed with the regulator that made the determination.
View actuals against commitments →

The full commitments report

Every commitment quoted with its page, the peer comparison across the schemes in scope, and the holdings tested against each rule, as a standalone report you can circulate. The published cut is quarter-delayed; clients see current data.

Move to live data

The report above is published on a quarter-delayed cut. Clients receive the same report on current data across every fund in scope. Higher-frequency updates are available on request.

Published

Quarter-delayed reports

Open to everyone. Full methodology, data sources and band rules, on data as at the end of the last quarter.

Subscription

Client subscription

Current data rather than last quarter's, the complete universe, full history, alerts, CSV and API. Priced per firm.

Client account

Your own portfolio

Upload holdings and keep them. Saved screens, exclusion policies and monitoring that persist between sessions.

See this report on today’s data, against your own book.

Clients receive the same report on current data across the complete universe, with the evidence behind every band. Higher-frequency updates and bespoke reporting are available on request.

Request a briefing → hello@sustainesg.io