Atlas / SEI Master Trust

Commitments report

Atlas / SEI Master Trust — can what it promised be tested?

6 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.

6published commitments, two layers

0not testable as written

1need data this report does not carry

2tested against holdings

Layer 1 · the trustee’s own statement of investment principles

3 commitments

Standard	What the scheme wrote	Threshold	Result
▸ Controversial weapons	“issuers involved in the sale, production, research or development of controversial weapons” named SEI fund only · p.4	any stated involvement	NOT YET TESTED Waiting on: the data the rule runs on
Mechanism exclusion Scope as written named SEI fund only Threshold any stated involvement Source document p.4 →
▸ Thermal coal	“more than 10% of annual revenue from thermal coal” named SEI fund only · p.4	>10% annual revenue	NOT YET TESTED Waiting on: the data the rule runs on
Mechanism exclusion Scope as written named SEI fund only Threshold >10% annual revenue Source document p.4 →
▸ Other	“companies that do not adhere to good governance practices” named SEI fund only · p.4	failure of good-governance test	NOT YET TESTED Waiting on: the data the rule runs on
Mechanism exclusion Scope as written named SEI fund only Threshold failure of good-governance test Source document p.4 →

Layer 2 · the underlying funds inside the default

3 rules

Standard	Commitment	Share of equities	Result
▸ Controversial weapons	“issuers involved in the sale, production, research or development of controversial weapons” SEI Factor Allocation Global Equity Fund · p.4	100.0%	TESTED, SOME HOLDINGS NOT SETTLED At any stated involvement: Rule: any involvement in controversial weapons (sale, production, research or development; the fund does not define the term). 0 over threshold of 912 issuers in scope; 1 nuclear-only, scope unconfirmed (0.21%); 7 answered from existing register rows, nothing collected; 824 screen-negative (520 on Scottish Widows' / Standard Life's review of the same company; a screen, not a document); 81 candidates not collected (4.97%; register-only run). Holdings 31 Dec 2025; rulebook 27 Sep 2024.
Mechanism commitment Scope as written SEI Factor Allocation Global Equity Fund Threshold any stated involvement Source document p.4 → What the test found. Rule: any involvement in controversial weapons (sale, production, research or development; the fund does not define the term). 0 over threshold of 912 issuers in scope; 1 nuclear-only, scope unconfirmed (0.21%); 7 answered from existing register rows, nothing collected; 824 screen-negative (520 on Scottish Widows' / Standard Life's review of the same company; a screen, not a document); 81 candidates not collected (4.97%; register-only run). Holdings 31 Dec 2025; rulebook 27 Sep 2024.
▸ Thermal coal	“more than 10% of annual revenue from thermal coal” SEI Factor Allocation Global Equity Fund · p.4	100.0%	TESTED, SOME HOLDINGS NOT SETTLED At >10% annual revenue: Rule: more than 10% of annual revenue from thermal coal (coal-fired generation outside the screen). 0 over threshold of 912 issuers in scope; 22 answered from existing register rows, nothing collected; 817 screen-negative (501 on Scottish Widows' / Standard Life's review of the same company; a screen, not a document); 73 candidates not collected (3.30%; register-only run). Other schemes' coal levels: Mercer >1%, Scottish Widows ≥5%, Standard Life >5%, Mercer ≥5%, Aegon >5%, Fidelity >5%, Royal London ≥60%. Holdings 31 Dec 2025; rulebook 27 Sep 2024.
Mechanism commitment Scope as written SEI Factor Allocation Global Equity Fund Threshold >10% annual revenue Source document p.4 → What the test found. Rule: more than 10% of annual revenue from thermal coal (coal-fired generation outside the screen). 0 over threshold of 912 issuers in scope; 22 answered from existing register rows, nothing collected; 817 screen-negative (501 on Scottish Widows' / Standard Life's review of the same company; a screen, not a document); 73 candidates not collected (3.30%; register-only run). Other schemes' coal levels: Mercer >1%, Scottish Widows ≥5%, Standard Life >5%, Mercer ≥5%, Aegon >5%, Fidelity >5%, Royal London ≥60%. Holdings 31 Dec 2025; rulebook 27 Sep 2024.
▸ Other	“companies that do not adhere to good governance practices” SEI Factor Allocation Global Equity Fund · p.4	100.0%	NOT YET TESTED 'companies that do not adhere to good governance practices': an issuer-status screen with no threshold, 'subject to stated data availability'. Not a revenue test (as the UNGC rule) and not forced into one; no verdict is derived
Mechanism commitment Scope as written SEI Factor Allocation Global Equity Fund Threshold failed good-governance test Source document p.4 → Not yet tested, and not forced into a test it does not ask for. 'companies that do not adhere to good governance practices': an issuer-status screen with no threshold, 'subject to stated data availability'. Not a revenue test (as the UNGC rule) and not forced into one; no verdict is derived A rule outside this report’s scope is never shown as met, and never as a pass.

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%	this scheme — 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%	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.

Tested on company documents, rule by rule

2 of this scheme’s rules were tested against its holdings above; there is no holdings page

The holdings page sets a scheme’s UN Global Compact rule beside adjudicated findings, and this scheme published none. Its activity rules were tested issuer by issuer on company documents already in the evidence register — each result sits beside its own threshold, because a short list under a loose rule is the rule’s weakness, not a clean book.

Is it moving?

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

4 holdings (0.8% of the scheme) are behind their own promise or have witnesses that disagree; 0 are ahead (0.0%). 99% 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 →