Aegon Workplace Default

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

Standard	What the scheme wrote	Threshold	Result
▸ Other	“The trustees have committed to net-zero carbon emissions of the default solution by 2050.” default solution · p.5	net zero by 2050	NO INTERIM MEASURE
Mechanism target Scope as written default solution Threshold net zero by 2050 Source document p.5 → 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 stated	NOT BINDING
Mechanism policy guidance Scope as written default fund reviews / new business Threshold not stated Source document p.7 → 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 stated	NOT BINDING
Mechanism policy guidance Scope as written default fund reviews / new business Threshold not stated Source document p.7 → 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 stated	NOT TESTABLE
Mechanism policy guidance Scope as written default fund reviews / new business Threshold not stated Source document p.7 → 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 stated	NOT YET TESTED Waiting on: the data the rule runs on
Mechanism policy guidance Scope as written default fund reviews / new business Threshold not stated Source document p.7 →

Layer 2 · the underlying funds inside the default

5 rules

Standard	Commitment	Share 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 Source document p.Objectives → 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% Source document p.Appendix 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 Source document p.Appendix 5 → 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 Source document p.Appendix 5 → 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 — 210 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 Source document p.Appendix 5 → 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	Commitments	Quantified	Equities bound	Position
Atlas / SEI→	13.6%34 holdings no UNGC rule	33.8%129 holdings 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	6	2	100.0%	1 of 8 by equities bound
Scottish Widows→	14.2%51 holdings	41.6%156 holdings	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	15	9	100.0%	2 of 8 by equities bound
Standard Life (PUTM)→	16.8%67 holdings	41.1%237 holdings	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	61	37	92.7%	3 of 8 by equities bound
Aegon→	17.0%73 holdings	41.7%245 holdings	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	10	4	79.2%	this scheme — 4 of 8 by equities bound
Smart→	16.9%58 holdings	42.0%163 holdings	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	6	4	50.9%	5 of 8 by equities bound
Mercer→	12.5%74 holdings UNGC rule binds some sleeves only holdings cover 44.9% of the pot (pre-transition sections) or 59.3% (Long Term Growth)	35.8%267 holdings UNGC rule binds some sleeves only holdings cover 44.9% of the pot (pre-transition sections) or 59.3% (Long Term Growth)	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	122	82	32.1–42.1%	6 of 8 by equities bound
Fidelity→	15.0%58 holdings	48.0%161 holdings	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	6	4	32.0%	7 of 8 by equities bound
Royal London→	9.9%65 holdings no UNGC rule	26.7%248 holdings 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	6	4	30.6%	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

210 of 1131 holdings — 22.28% 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 →

Is it moving?

The holdings’ emissions against their own promises, on registry and satellite evidence

12 holdings (1.3% of the scheme) are behind their own promise or have witnesses that disagree; 2 are ahead (0.2%). 100% of the scheme by weight has no Pace verdict the evidence can support. Words with evidence, never a score; nothing here moves a band.

Transition evidence →