Standard Life (PUTM ACS)

Commitments report

Standard Life (PUTM ACS) — can what it promised be tested?

61 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.

61published commitments, two layers

0not testable as written

12need data this report does not carry

42tested against holdings

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

7 commitments

Standard	What the scheme wrote	Threshold	Result
▸ Other	“25% reduction by 2025” listed equity and credit · p.27	25% versus 2019	NOT YET TESTED Waiting on: the data the rule runs on
Mechanism target Scope as written listed equity and credit Threshold 25% versus 2019 Source document p.27 →
▸ Other	“at least 50% by 2030” listed equity and credit · p.27	>=50% versus 2019	NOT YET TESTED Waiting on: the data the rule runs on
Mechanism target Scope as written listed equity and credit Threshold >=50% versus 2019 Source document p.27 →
▸ Other	“an aspiration, as opposed to a target” whole scheme · p.27	net zero by 2050	NOT YET TESTED Waiting on: the data the rule runs on
Mechanism aspiration Scope as written whole scheme Threshold net zero by 2050 Source document p.27 →
▸ Thermal coal	“2 Our threshold for exclusion is 20% of revenues from this source, and a waiver is adopted where companies have between 20-30% of revenues from this source and have Paris aligned science based targets approved by the SBTi.” Phoenix Group (not the trust) · p.PDF p27	>=20 (waiver 20-30 with SBTi Paris-aligned targets)	NOT YET TESTED Waiting on: the data the rule runs on
Mechanism exclusion Scope as written Phoenix Group (not the trust) Threshold >=20 (waiver 20-30 with SBTi Paris-aligned targets) Source document p.PDF p27 →
▸ Oil sands and oil and gas	“3 Our threshold for exclusion is 20% of revenues from this source.” Phoenix Group (not the trust) · p.PDF p27	>=20	NOT YET TESTED Waiting on: the data the rule runs on
Mechanism exclusion Scope as written Phoenix Group (not the trust) Threshold >=20 Source document p.PDF p27 →
▸ Oil sands and oil and gas	“3 Our threshold for exclusion is 20% of revenues from this source.” Phoenix Group (not the trust) · p.PDF p27	>=20	NOT YET TESTED Waiting on: the data the rule runs on
Mechanism exclusion Scope as written Phoenix Group (not the trust) Threshold >=20 Source document p.PDF p27 →
▸ Tobacco	“4 Our threshold for exclusion is 1% of revenues from this source.” Phoenix Group (not the trust) · p.PDF p27	>=1	NOT YET TESTED Waiting on: the data the rule runs on
Mechanism exclusion Scope as written Phoenix Group (not the trust) Threshold >=1 Source document p.PDF p27 →

Layer 2 · the underlying funds inside the default

54 rules

Standard	Commitment	Share of equities	Result
▸ Controversial weapons	“Controversial weapons – Zero tolerance policy” PUTM ACS Sustainable Index North American Equity Fund · p.PDF p1 (exclusion box), identical on all six funds	46.1%	VERIFIED At zero tolerance: 501 issuers screened, 7 worked on company-primary evidence; 0 over threshold; 3 nuclear-only, scope unconfirmed (0.3117% of LPNL)
Mechanism commitment Scope as written PUTM ACS Sustainable Index North American Equity Fund Threshold zero tolerance Source document p.PDF p1 (exclusion box), identical on all six funds → Not yet tested. A number, a direction and a unit. The row is waiting on issuer activity revenue (company-primary). A rule outside this report’s scope is never shown as met.
▸ Tobacco	“Tobacco production – Companies deriving more than 1% of revenue from this activity” PUTM ACS Sustainable Index North American Equity Fund · p.PDF p1 (exclusion box), identical on all six funds	46.1%	VERIFIED At > 1% of revenue (production): 501 issuers screened, 11 worked on company-primary evidence; 0 over threshold
Mechanism commitment Scope as written PUTM ACS Sustainable Index North American Equity Fund Threshold > 1% of revenue (production) Source document p.PDF p1 (exclusion box), identical on all six funds → Not yet tested. A number, a direction and a unit. The row is waiting on issuer activity revenue (company-primary). A rule outside this report’s scope is never shown as met.
▸ Tobacco	“Tobacco distribution, retail and supply – Companies deriving more than 25% of revenue” PUTM ACS Sustainable Index North American Equity Fund · p.PDF p1 (exclusion box), identical on all six funds	46.1%	TESTED, SOME HOLDINGS DISCLOSE NO FIGURE At > 25% of revenue (distribution, retail and supply): 501 issuers screened, 11 worked on company-primary evidence; 0 over threshold; 9 not disclosed (0.6953% of LPNL)
Mechanism commitment Scope as written PUTM ACS Sustainable Index North American Equity Fund Threshold > 25% of revenue (distribution, retail and supply) Source document p.PDF p1 (exclusion box), identical on all six funds → What the test found. 501 issuers screened, 11 worked on company-primary evidence; 0 over threshold; 9 not disclosed (0.6953% of LPNL)
▸ Thermal coal	“Thermal coal mining and energy production – Companies deriving more than 5% of revenue” PUTM ACS Sustainable Index North American Equity Fund · p.PDF p1 (exclusion box), identical on all six funds	46.1%	TESTED, SOME HOLDINGS DISCLOSE NO FIGURE At > 5% of revenue (mining and energy production): 501 issuers screened, 8 worked on company-primary evidence; 0 over threshold; 4 measured on a different boundary (0.2154% of LPNL); 1 not disclosed (0.0071% of LPNL)
Mechanism commitment Scope as written PUTM ACS Sustainable Index North American Equity Fund Threshold > 5% of revenue (mining and energy production) Source document p.PDF p1 (exclusion box), identical on all six funds → What the test found. 501 issuers screened, 8 worked on company-primary evidence; 0 over threshold; 4 measured on a different boundary (0.2154% of LPNL); 1 not disclosed (0.0071% of LPNL)
▸ Arctic drilling	“Arctic drilling – Companies deriving more than 5% of revenue” PUTM ACS Sustainable Index North American Equity Fund · p.PDF p1 (exclusion box), identical on all six funds	46.1%	TESTED, SOME HOLDINGS DISCLOSE NO FIGURE At > 5% of revenue (Arctic drilling): 501 issuers screened, 5 worked on company-primary evidence; 1 over threshold (0.0482% of LPNL: Conoco Phillips); 1 not disclosed (0.1772% of LPNL)
Mechanism commitment Scope as written PUTM ACS Sustainable Index North American Equity Fund Threshold > 5% of revenue (Arctic drilling) Source document p.PDF p1 (exclusion box), identical on all six funds → What the test found. 501 issuers screened, 5 worked on company-primary evidence; 1 over threshold (0.0482% of LPNL: Conoco Phillips); 1 not disclosed (0.1772% of LPNL)
▸ Oil sands	“Oil sands extraction – Companies deriving more than 5% of revenue” PUTM ACS Sustainable Index North American Equity Fund · p.PDF p1 (exclusion box), identical on all six funds	46.1%	VERIFIED At > 5% of revenue (oil sands extraction): 501 issuers screened, 5 worked on company-primary evidence; 1 over threshold (0.0033% of LPNL: Imperial Oil); 1 measured on a different boundary (0.1772% of LPNL)
Mechanism commitment Scope as written PUTM ACS Sustainable Index North American Equity Fund Threshold > 5% of revenue (oil sands extraction) Source document p.PDF p1 (exclusion box), identical on all six funds → Not yet tested. A number, a direction and a unit. The row is waiting on issuer activity revenue (company-primary). A rule outside this report’s scope is never shown as met.
▸ UN Global Compact	“Breaches of the United Nations Global Compact (UNGC)” PUTM ACS Sustainable Index North American Equity Fund · p.PDF p1 (exclusion box), identical on all six funds	46.1%	TWO MEASURES — 228 HOLDINGS CARRY A FINDING WE MAP TO IT
Mechanism commitment Scope as written PUTM ACS Sustainable Index North American Equity Fund Threshold breach Source document p.PDF p1 (exclusion box), identical on all six funds → Not yet tested. A number, a direction and a unit. The row is waiting on UN Global Compact conduct evidence (norms-based). A rule outside this report’s scope is never shown as met.
▸ Other	“Lowest ESG score rating – Based on external ESG assessments” PUTM ACS Sustainable Index North American Equity Fund · p.PDF p1 (exclusion box), identical on all six funds	46.1%	NOT YET TESTED Waiting on: vendor ESG rating
Mechanism commitment Scope as written PUTM ACS Sustainable Index North American Equity Fund Threshold external rating Source document p.PDF p1 (exclusion box), identical on all six funds → Not yet tested. A number, a direction and a unit. The row is waiting on vendor ESG rating. A rule outside this report’s scope is never shown as met.
▸ Norms and controversies	“Severe ESG controversies – As identified by third-party data providers” PUTM ACS Sustainable Index North American Equity Fund · p.PDF p1 (exclusion box), identical on all six funds	46.1%	NOT YET TESTED Waiting on: vendor ESG rating
Mechanism commitment Scope as written PUTM ACS Sustainable Index North American Equity Fund Threshold third-party controversy flag Source document p.PDF p1 (exclusion box), identical on all six funds → Not yet tested. A number, a direction and a unit. The row is waiting on vendor ESG rating. A rule outside this report’s scope is never shown as met.
▸ Controversial weapons	“Controversial weapons – Zero tolerance policy” PUTM ACS Sustainable Index European Equity Fund · p.PDF p1 (exclusion box), identical on all six funds	15.2%	VERIFIED At zero tolerance: 359 issuers screened, 10 worked on company-primary evidence; 0 over threshold; 4 nuclear-only, scope unconfirmed (0.3876% of LPNL)
Mechanism commitment Scope as written PUTM ACS Sustainable Index European Equity Fund Threshold zero tolerance Source document p.PDF p1 (exclusion box), identical on all six funds → Not yet tested. A number, a direction and a unit. The row is waiting on issuer activity revenue (company-primary). A rule outside this report’s scope is never shown as met.
▸ Tobacco	“Tobacco production – Companies deriving more than 1% of revenue from this activity” PUTM ACS Sustainable Index European Equity Fund · p.PDF p1 (exclusion box), identical on all six funds	15.2%	VERIFIED At > 1% of revenue (production): 359 issuers screened, 8 worked on company-primary evidence; 0 over threshold
Mechanism commitment Scope as written PUTM ACS Sustainable Index European Equity Fund Threshold > 1% of revenue (production) Source document p.PDF p1 (exclusion box), identical on all six funds → Not yet tested. A number, a direction and a unit. The row is waiting on issuer activity revenue (company-primary). A rule outside this report’s scope is never shown as met.
▸ Tobacco	“Tobacco distribution, retail and supply – Companies deriving more than 25% of revenue” PUTM ACS Sustainable Index European Equity Fund · p.PDF p1 (exclusion box), identical on all six funds	15.2%	TESTED, SOME HOLDINGS DISCLOSE NO FIGURE At > 25% of revenue (distribution, retail and supply): 359 issuers screened, 8 worked on company-primary evidence; 0 over threshold; 6 not disclosed (0.0501% of LPNL)
Mechanism commitment Scope as written PUTM ACS Sustainable Index European Equity Fund Threshold > 25% of revenue (distribution, retail and supply) Source document p.PDF p1 (exclusion box), identical on all six funds → What the test found. 359 issuers screened, 8 worked on company-primary evidence; 0 over threshold; 6 not disclosed (0.0501% of LPNL)
▸ Thermal coal	“Thermal coal mining and energy production – Companies deriving more than 5% of revenue” PUTM ACS Sustainable Index European Equity Fund · p.PDF p1 (exclusion box), identical on all six funds	15.2%	TESTED, SOME HOLDINGS DISCLOSE NO FIGURE At > 5% of revenue (mining and energy production): 359 issuers screened, 14 worked on company-primary evidence; 0 over threshold; 1 measured on a different boundary (0.0062% of LPNL); 2 not disclosed (0.0415% of LPNL)
Mechanism commitment Scope as written PUTM ACS Sustainable Index European Equity Fund Threshold > 5% of revenue (mining and energy production) Source document p.PDF p1 (exclusion box), identical on all six funds → What the test found. 359 issuers screened, 14 worked on company-primary evidence; 0 over threshold; 1 measured on a different boundary (0.0062% of LPNL); 2 not disclosed (0.0415% of LPNL)
▸ Arctic drilling	“Arctic drilling – Companies deriving more than 5% of revenue” PUTM ACS Sustainable Index European Equity Fund · p.PDF p1 (exclusion box), identical on all six funds	15.2%	TESTED, SOME HOLDINGS DISCLOSE NO FIGURE At > 5% of revenue (Arctic drilling): 359 issuers screened, 8 worked on company-primary evidence; 0 over threshold; 3 not disclosed (0.2469% of LPNL)
Mechanism commitment Scope as written PUTM ACS Sustainable Index European Equity Fund Threshold > 5% of revenue (Arctic drilling) Source document p.PDF p1 (exclusion box), identical on all six funds → What the test found. 359 issuers screened, 8 worked on company-primary evidence; 0 over threshold; 3 not disclosed (0.2469% of LPNL)
▸ Oil sands	“Oil sands extraction – Companies deriving more than 5% of revenue” PUTM ACS Sustainable Index European Equity Fund · p.PDF p1 (exclusion box), identical on all six funds	15.2%	VERIFIED At > 5% of revenue (oil sands extraction): 359 issuers screened, 3 worked on company-primary evidence; 0 over threshold
Mechanism commitment Scope as written PUTM ACS Sustainable Index European Equity Fund Threshold > 5% of revenue (oil sands extraction) Source document p.PDF p1 (exclusion box), identical on all six funds → Not yet tested. A number, a direction and a unit. The row is waiting on issuer activity revenue (company-primary). A rule outside this report’s scope is never shown as met.
▸ UN Global Compact	“Breaches of the United Nations Global Compact (UNGC)” PUTM ACS Sustainable Index European Equity Fund · p.PDF p1 (exclusion box), identical on all six funds	15.2%	VERIFIED At breach: norms-based (conduct), so not on company-primary revenue evidence: tested against the engine's adjudicated UN Global Compact findings on the holdings page
Mechanism commitment Scope as written PUTM ACS Sustainable Index European Equity Fund Threshold breach Source document p.PDF p1 (exclusion box), identical on all six funds → Not yet tested. A number, a direction and a unit. The row is waiting on UN Global Compact conduct evidence (norms-based). A rule outside this report’s scope is never shown as met.
▸ Other	“Lowest ESG score rating – Based on external ESG assessments” PUTM ACS Sustainable Index European Equity Fund · p.PDF p1 (exclusion box), identical on all six funds	15.2%	NOT YET TESTED Waiting on: vendor ESG rating
Mechanism commitment Scope as written PUTM ACS Sustainable Index European Equity Fund Threshold external rating Source document p.PDF p1 (exclusion box), identical on all six funds → Not yet tested. A number, a direction and a unit. The row is waiting on vendor ESG rating. A rule outside this report’s scope is never shown as met.
▸ Norms and controversies	“Severe ESG controversies – As identified by third-party data providers” PUTM ACS Sustainable Index European Equity Fund · p.PDF p1 (exclusion box), identical on all six funds	15.2%	NOT YET TESTED Waiting on: vendor ESG rating
Mechanism commitment Scope as written PUTM ACS Sustainable Index European Equity Fund Threshold third-party controversy flag Source document p.PDF p1 (exclusion box), identical on all six funds → Not yet tested. A number, a direction and a unit. The row is waiting on vendor ESG rating. A rule outside this report’s scope is never shown as met.

Showing 18 of 54 rules. Scroll down to unlock the full report and see them all, with the determination and source behind each.

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.

Exceptions

What the company-primary test does not settle — named, not resolved

Each says something true about what a provider or a company does and does not publish. None is counted as a finding, and none as a pass.

Held pending a decision · 1 holding, 0.0014% of the fund

A finding exists on the evidence and is withheld until a named person decides. It is shown as held, with the reason, and never as a finding. Solar Industries India stays held, in this scheme and in Scottish Widows, on the same evidence and pending the same decision.

Company	Rule	Measured	Share of fund	What the evidence says
Solar Industries India India	Controversial weapons, any involvement	held	0.0014%	The company's annual report names its Ministry of Defence order for Pinaka 'Area Denial Munitions'; the Ministry's own release calls the product 'ADM Type-1 (DPICM)', a sub-munition. Whether a government's description may complete a finding the company's own documents do not make is a policy decision not yet taken. Until it is, the row is held.

Measured on another boundary · 14 holdings, 0.47% of the fund

The company publishes a figure, but not on the basis the rule is written on — a share of generation rather than of revenue, or an associate’s revenue looked through. None becomes a finding without a policy decision. Washington H. Soul Pattinson reads 74.1% thermal coal only as a look-through: 39.4% of New Hope Corporation's revenue, an equity-accounted associate, against WHSP's own revenue. Its consolidated coal revenue is nil. Equity-accounted coal is not bounded by the holder's own nil lines (the CKI and Sabanci precedent), so it is neither under nor over until the policy owner decides whether it counts.

Company	Rule	Measured	Share of fund	What the evidence says
Exxon Mobil United States	Oil sands > 5%	2.68% (calculated)	0.1772%	volume x average realised price is a proxy for oil sands production revenue (not a booked revenue line); bitumen realisation excludes diluent; 100% of consolidated Imperial Oil volumes (ExxonMobil owns 69.6%, NCI not deducted) so the proxy overstates the attributable share
NextEra Energy United States	Thermal coal > 5%	0.31% (share of generation, not of revenue)	0.1512%	share of generating CAPACITY, not revenue (the 10-K prints no generation by fuel in MWh)
CenterPoint Energy United States	Thermal coal > 5%	62.39% (share of generation, not of revenue)	0.0285%	share of generating CAPACITY of the company's own fleet, not revenue (no MWh by fuel printed)
Entergy United States	Thermal coal > 5%	3.00% (share of generation, not of revenue)	0.0223%	share of energy sources (MWh basis, including purchased power and MISO purchases), not revenue
Korea Electric Power South Korea	Thermal coal > 5%	35.88% (share of generation, not of revenue)	0.0197%	share of own generation (GWh), not revenue
Companhia Paranaese De Energia-Copel Brazil	Thermal coal > 5%	0.00% (share of generation, not of revenue)	0.0152%	share of installed operating capacity, not revenue (no coal generation or coal revenue figure is printed)
Osaka Gas Japan	Thermal coal > 5%	4.93% (share of generation, not of revenue)	0.0138%	share of installed capacity (generation by fuel not printed), not revenue
NRG Energy United States	Thermal coal > 5%	56.16% (share of generation, not of revenue)	0.0133%	share of the company's own net generation (MWh), not revenue; NRG revenue is dominated by retail energy sales
Washington H. Soul Pattinson and Company Australia	Thermal coal > 5%	74.14% (calculated)	0.0064%	equity-accounted: New Hope's revenue is not the holder's revenue (WHSP records share of profit A$115.8m); consolidated thermal coal revenue = nil. The % is a look-through attribution only (Scottish Widows Tata Power precedent). On a strict consolidated reading the share is 0; pro-rata it is far above 5%
BKW Energie Switzerland	Thermal coal > 5%	4.30% (share of generation, not of revenue)	0.0062%	share of generation, not revenue
Enel Americas Chile	Thermal coal > 5%	2.38% (share of generation, not of revenue)	0.0053%	share of generation, not revenue
YTL Malaysia	Thermal coal > 5%	0.80% (calculated)	0.0028%	coal generation sits only in PT Jawa Power, an associate accounted for under the equity method; its revenue is not in YTL Corp revenue at all (consolidated coal revenue = nil). The figure is a look-through pro-rata share (effective interest 10.66%; at the 35% direct interest held via the YTL Power subgroup it would be RM 810,187k = 2.63%)

The other 2 — every one named

Company	Rule	Measured	Share of fund	What the evidence says
YTL Power International Malaysia	Thermal coal > 5%	2.12% (calculated)	0.0027%	coal generation sits only in PT Jawa Power, an associate accounted for under the equity method; its revenue is not in YTL Power revenue (consolidated coal revenue = nil). Look-through pro-rata share at the 20% effective interest; at the subgroup 35% direct interest it would be RM 810,187k = 3.72%
Shree Cements India	Thermal coal > 5%	5.70% (calculated)	0.0009%	'Power Sales' is all electricity sold; the report calls the IPP 'thermal' (fly ash and gypsum from 'our thermal power plants') without naming the fuel split (coal vs petcoke), and does not say whether any surplus WHR/solar/wind power is in the line. Best available proxy for coal-power revenue; the share sits only 0.70pp over the threshold

Scope unconfirmed · 10 holdings, 1.29% of the fund

The fund does not publish whether its rule covers this involvement, and no document on file settles it. The test is left unsourced and derives no verdict. The funds publish 'Controversial weapons - zero tolerance' and never say whether that covers nuclear weapons. The 'nuclear weapons outside the NPT' test tabled for them has no source document. All 10 work for NPT nuclear-weapon states, so under that rule as stated none would breach it.

Company	Rule	Measured	Share of fund	What the evidence says
Rolls-Royce United Kingdom	Controversial weapons, any involvement	nuclear only	0.3664%	no core-set weapon; nuclear link is propulsion reactors for the Royal Navy submarine fleet, which includes the nuclear-armed ballistic-missile submarines (platform, not the weapon); the report itself does not name the deterrent Works for the United Kingdom programme, an NPT nuclear-weapon state.
BAE Systems United Kingdom	Controversial weapons, any involvement	nuclear only	0.2016%	Trident II D5 strategic weapons system engineering and Dreadnought SSBN build are nuclear-weapon programme/delivery-system work, outside the convention core set; no core-set weapon found Works for the United Kingdom programme, an NPT nuclear-weapon state.
Safran France	Controversial weapons, any involvement	nuclear only	0.1793%	M51 submarine-launched ballistic missile (via 50% JV ArianeGroup) is a nuclear-weapon delivery system, outside the convention core set; core-set involvement not tested against a Safran filing Works for the French programme, an NPT nuclear-weapon state.
Airbus Netherlands	Controversial weapons, any involvement	nuclear only	0.1650%	no core-set weapon (company statement); nuclear-weapon delivery systems via equity-accounted JVs ArianeGroup (M51 SLBM) and MBDA Works for the French programme, an NPT nuclear-weapon state.
Honeywell International United States	Controversial weapons, any involvement	nuclear only	0.1434%	management and operation of NNSA nuclear-weapons production site (non-nuclear components) is nuclear-weapons programme work, outside the convention core set; no core-set weapon found Works for the United States programme, an NPT nuclear-weapon state.
Boeing United States	Controversial weapons, any involvement	nuclear only	0.1181%	ICBM guidance subsystems support is nuclear-weapon delivery-system work, outside the convention core set; no core-set weapon found Works for the United States programme, an NPT nuclear-weapon state.
L3 Harris Technology United States	Controversial weapons, any involvement	nuclear only	0.0503%	propulsion for the Sentinel ICBM (replacement for Minuteman III, a nuclear delivery system) is nuclear-weapon programme work, outside the convention core set; no core-set weapon found Works for the United States programme, an NPT nuclear-weapon state.
Thales France	Controversial weapons, any involvement	nuclear only	0.0371%	core set denied by the company; its definition carves out NPT nuclear weapons, and it works on the French SSBN (nuclear deterrent) programme - nuclear-only Works for the French programme, an NPT nuclear-weapon state.
Babcock International United Kingdom	Controversial weapons, any involvement	nuclear only	0.0195%	engineering support to the Atomic Weapons Establishment (warhead production) and deterrent-submarine support is nuclear-weapon programme work, outside the convention core set; the company states it does not make nuclear or controversial weapons Works for the United Kingdom programme, an NPT nuclear-weapon state.
Dassault Aviation France	Controversial weapons, any involvement	nuclear only	0.0062%	Rafale is the delivery platform for the ASMP-A nuclear missile (company words); no core-set weapon found Works for the French programme, an NPT nuclear-weapon state.

No split is published · 95 holdings, 2.25% of the fund

The company is in the activity and prints no line that separates it at the rule’s threshold. More reading will not produce a number the company has not published. Unmeasured is not clean, and it is not a breach. No split is published. This is the residual the test closes on: the companies are named, the activity is named, and none prints a line that holds all of it under the threshold.

Company	Rule	Measured	Share of fund	What the evidence says
Walmart United States	Tobacco distribution, retail and supply > 25%	no split is published	0.3451%	no tobacco numerator; the category that would contain tobacco is not identified and Grocery alone is 40.0% of total revenues, so no bound
Costco Wholesale United States	Tobacco distribution, retail and supply > 25%	no split is published	0.2579%	the containing line Foods and Sundries is 39.8% of total revenue (40.6% of net sales), above 25%, so it gives no upper bound
TotalEnergies France	Arctic drilling > 5%	no split is published	0.2140%	no Arctic or field-level revenue line; the geographic note is by customer region and Norway is not split
Itochu Japan	Thermal coal > 5%	no split is published	0.1885%	no split - Metals & Minerals mixes iron ore, coking coal and trading; no thermal-coal mining or coal-power revenue line; the segment exceeds 5% so gives no upper bound
Exxon Mobil United States	Arctic drilling > 5%	no split is published	0.1772%	Upstream U.S. also contains Permian, Gulf and other lower-48 production; no Alaska split
Mitsubishi Japan	Thermal coal > 5%	no split is published	0.0992%	coal-fired generation held through IPP project companies, largely equity-accounted: associate revenue is not the holder's revenue; the capacity share is not a revenue share and MC is not a utility, so no generation_share_proxy
Mitsui Japan	Thermal coal > 5%	no split is published	0.0979%	coal-fired plants held as IPP project interests (Mitsui's share of net capacity), equity-accounted: associate revenue is not the holder's revenue; capacity share is not a revenue share
Marubeni Japan	Thermal coal > 5%	no split is published	0.0768%	IPP projects are mostly associates/JVs (Power segment share of profit of associates JPY 53,204m): associate revenue is not the holder's revenue; the Power segment line (6.16%) contains the activity but exceeds 5%, so it is not an upper bound
Tesco United Kingdom	Tobacco distribution, retail and supply > 25%	no split is published	0.0683%	the printed tobacco figure covers Booker wholesale only; no line contains all Tesco tobacco below 25%
Aeon Japan	Tobacco distribution, retail and supply > 25%	no split is published	0.0555%	no tobacco numerator; segment lines (GMS 3,559,481m / SM 3,060,065m) are the only containing lines and exceed 25%
Sumitomo Japan	Thermal coal > 5%	no split is published	0.0537%	no split - coal mining sits in Mineral Resources (4.09%, bounds the mining part only) and coal-fired power in Energy Transformation (9.74%, mixed with gas, LNG, renewables, retail); the two lines together (13.8%) exceed 5%, so no upper bound for the policy numerator
Toyota Tsusho Japan	Thermal coal > 5%	no split is published	0.0505%	the coal-fired plant is held as an investment (associate), not a subsidiary: associate revenue is not the holder's revenue

The other 83 — every one named

Company	Rule	Measured	Share of fund	What the evidence says
Seven & I Holdings Japan	Tobacco distribution, retail and supply > 25%	no split is published	0.0375%	Nonfood is printed on a chain-sales basis (incl. franchisees), not as consolidated revenue, and 7-Eleven Australia and other overseas CVS have no category table, so no revenue bound can be formed
Nippon Steel & Sumitomo Metal Japan	Thermal coal > 5%	no split is published	0.0310%	no split - no line isolates coal-fired power sales; the only segment naming electricity supply (Engineering and Construction, 4.27% of revenue) is the engineering subsidiary and need not contain the steelworks IPPs, so it is not a valid upper bound
Veolia Environnement France	Thermal coal > 5%	no split is published	0.0299%	the only printed line containing the coal (District Heating & Cooling Networks, 17.3% of revenue) also contains gas, biomass, waste-heat and heat-pump networks, so it is neither an upper bound at or below 5% nor a wholly-coal lower bound
Woolworths Australia	Tobacco distribution, retail and supply > 25%	no split is published	0.0280%	no tobacco numerator printed; the containing segment (Australian Food) is far above 25%
Equinor Norway	Arctic drilling > 5%	no split is published	0.0218%	production share only; revenue is not split by field, sea area or latitude
Chubu Electric Power Japan	Thermal coal > 5%	no split is published	0.0215%	the coal generation sits in an equity-accounted JV; Chubu records only its share of JERA's profit, so no consolidated coal revenue exists to measure
Loblaw Canada	Tobacco distribution, retail and supply > 25%	no split is published	0.0206%	no tobacco numerator; the plausible containing line Food retail (C$45,234m, 70.8% of revenue) is above 25%
Sainsbury (J) United Kingdom	Tobacco distribution, retail and supply > 25%	no split is published	0.0205%	no tobacco numerator printed; the likely containing category (Grocery) is far above 25%
Kroger United States	Tobacco distribution, retail and supply > 25%	no split is published	0.0180%	no tobacco numerator; the plausible containing line (Non perishable, 52.5% of sales) is above 25% and is not stated to contain tobacco
Stora Enso (registered) Finland	Tobacco distribution, retail and supply > 25%	no split is published	0.0166%	no tobacco-customer numerator printed
Dollar General United States	Tobacco distribution, retail and supply > 25%	no split is published	0.0144%	the containing line Consumables is 82.0% of net sales, so it gives no upper bound
Smurfit Westrock Ireland	Tobacco distribution, retail and supply > 25%	no split is published	0.0143%	no tobacco numerator is printed
POSCO South Korea	Thermal coal > 5%	no split is published	0.0137%	equity-accounted: associate revenue is not the holder's revenue (look-through 34% x 596,497 + 30% x 460,672 = KRW 341,011m = 0.46% of revenue, all below 5%); coal-sales subsidiaries' grade (thermal vs coking) and external sales are not disclosed
Sojitz Holdings Japan	Thermal coal > 5%	no split is published	0.0120%	no split - thermal coal sits in Metals, Mineral Resources & Recycling with coking coal (the main coal business), ores and trading; segment is 19.1%, no bound
Carrefour France	Tobacco distribution, retail and supply > 25%	no split is published	0.0116%	no tobacco numerator printed
Polski Koncern Naftowy Poland	Thermal coal > 5%	no split is published	0.0116%	the only printed containing line (Energy segment, 10.5%) also holds gas-fired, renewable and oil-fired generation, distribution and retail electricity/heat sales (28.6 TWh sold externally vs 16.8 TWh produced)
Dai Nippon Printing Japan	Tobacco distribution, retail and supply > 25%	no split is published	0.0116%	no tobacco numerator; packaging sits in Life & Healthcare (JPY 495,855m, 34.0%), which is above 25% and gives no bound
OMV Austria	Arctic drilling > 5%	no split is published	0.0111%	production share only, and at country level (Norway) not field level
Amcor Jersey	Tobacco distribution, retail and supply > 25%	no split is published	0.0108%	no tobacco numerator; the specialty cartons line is not stated to contain all tobacco packaging (tobacco films/liners could sit in Films and other flexible products), so no bound is claimed
Pan Pacific International Holdings Japan	Tobacco distribution, retail and supply > 25%	no split is published	0.0106%	tobacco not placed in any printed line; the discount-store 食品 line alone is 27.3% of sales, so the all-lines test gives no bound
DCC (London listed) Ireland	Tobacco distribution, retail and supply > 25%	no split is published	0.0103%	no tobacco numerator; the containing line (Energy mobility, mostly fuel) is 26.6% of revenue, just above the threshold
Kesko Finland	Tobacco distribution, retail and supply > 25%	no split is published	0.0098%	no tobacco numerator printed; the likely containing division (Grocery trade) is far above 25%
Fomento Economico Mexicano Mexico	Tobacco distribution, retail and supply > 25%	no split is published	0.0096%	n/a - no numerator printed; the containing Proximity Americas line alone is 39.1% of revenue (> 25%), so no bound
Sabanci Holding Turkey	Thermal coal > 5%	no split is published	0.0089%	on the consolidated basis the numerator is nil (Enerjisa Uretim is a 50/50 JV with E.ON, equity-accounted); the look-through line is a ceiling because Enerjisa Uretim's sales also include hydro, wind, solar, gas-fired generation and trading
Wal-Mart de Mexico Mexico	Tobacco distribution, retail and supply > 25%	no split is published	0.0084%	n/a - no numerator printed; no printed line <= 25% contains all possible tobacco sales (formats and countries are each far larger or not category-specific)
Astra International Indonesia	Thermal coal > 5%	no split is published	0.0080%	the only printed coal revenue line combines thermal coal with metallurgical coal (3.2 of 10.2 Mt own sales) and third-party coal traded (2.9 Mt); the line is 7.9% of Astra revenue but is not wholly thermal, so it is neither a valid upper bound (>5%) nor a lower bound
Metro Canada	Tobacco distribution, retail and supply > 25%	no split is published	0.0079%	no tobacco numerator or containing line is printed
CK Infrastructure Holdings Bermuda	Thermal coal > 5%	no split is published	0.0077%	the bound is on CKI's reported turnover; the coal generation sits in an equity-accounted associate (share of profit only), so this is an accounting-construction zero, not an absence of coal in the group
Hanwha South Korea	Thermal coal > 5%	no split is published	0.0076%	n/a - no numerator printed; the only segment that could hold coal sales (Trading and wholesale retails, 7.34%) exceeds 5% so gives no bound, and trading is outside the numerator anyway
Uni-President Enterprises Taiwan	Tobacco distribution, retail and supply > 25%	no split is published	0.0071%	n/a - no numerator printed; the containing convenience-store division alone is 31.43% of revenue (> 25%), so no bound
First Quantum Minerals Canada	Thermal coal > 5%	no split is published	0.0071%	n/a - no numerator printed; any grid sales would be coal-fired generation revenue (in the numerator), but the plant was idle through FY2024 and pre-halt was primarily captive supply to the mine
Weston George Canada	Tobacco distribution, retail and supply > 25%	no split is published	0.0063%	no tobacco numerator; the plausible containing line Loblaw food retail sales (C$45,234m, 70.1% of revenue) is above 25%
Matsumotokiyoshi Japan	Tobacco distribution, retail and supply > 25%	no split is published	0.0053%	tobacco not placed in any printed line; the largest line (医薬品, 34.7% of revenue) exceeds 25%, so the all-lines test gives no bound
Dubai Electricity & Water Authority United Arab Emirates	Thermal coal > 5%	no split is published	0.0052%	no coal revenue or coal generation figure printed; the only quantity is an unlabelled non-gas residual of Hassyan generation (derived 2.31% of total generation), which is neither a revenue share nor labelled coal
Jeronimo Martins Portugal	Tobacco distribution, retail and supply > 25%	no split is published	0.0050%	no tobacco numerator printed
Jindal Steel & Power India	Thermal coal > 5%	no split is published	0.0049%	no printed line isolates thermal coal sales; the only candidate line, consolidated finished-goods 'Others' Rs 2,716.10 crore (5.42%), also holds all other non-steel products
Shoprite Holdings South Africa	Tobacco distribution, retail and supply > 25%	no split is published	0.0045%	n/a - no numerator printed; the only containing lines (sale of merchandise; Supermarkets RSA segment) are far above 25%, so no bound
Empresas Copec Chile	Tobacco distribution, retail and supply > 25%	no split is published	0.0044%	n/a - no numerator printed; the containing Copec subsidiary line (~71% of group revenue) exceeds 25%, so no bound
DKSH Holding Switzerland	Tobacco distribution, retail and supply > 25%	no split is published	0.0041%	no tobacco numerator printed
Endeavour Group Australia	Tobacco distribution, retail and supply > 25%	no split is published	0.0040%	no tobacco numerator printed
Taiheiyo Cement Japan	Thermal coal > 5%	no split is published	0.0038%	no split - the containing lines (Other 6.83%, Environmental 7.16%) exceed 5% so give no upper bound; coal as kiln fuel and coal-ash processing are not in the numerator
CP All Thailand	Tobacco distribution, retail and supply > 25%	no split is published	0.0036%	the CVS non-food line (23.7% x 462,854 = ~109,700m, ~11.1% of group sale of goods) is not confirmed to contain cigarettes and excludes CP Axtra's tobacco; the wholesale and retail segment (48% of revenues before elimination) and CVS (46%) both exceed 25%, so no printed bound
Ayala Philippines	Thermal coal > 5%	no split is published	0.0035%	no coal line exists; the smallest printed line containing the SLTEC sales is the Power Generation segment's external sales P36,861m (9.96% of total revenue, 11.3% of sales), which also holds renewables, diesel and retail electricity supply, so it cannot bound the share below 5%
Axfood Sweden	Tobacco distribution, retail and supply > 25%	no split is published	0.0030%	no tobacco numerator printed
KOC Holding Turkey	Tobacco distribution, retail and supply > 25%	no split is published	0.0029%	the 'Other' segment (combined revenue TL 217,750m, incl. Setur duty-free, Divan cafes/hotels, Duzey FMCG distribution and vending) holds every consolidated store/distribution business; Opet and Opet Market (fuel stations and shops) are joint ventures outside consolidated revenue. 217,750/2,757,295 = 7.90%. Not exact: Akpa (Energy, 'Marketing' of durables, LPG and fuel) is outside it
CITIC Pacific Hong Kong	Thermal coal > 5%	no split is published	0.0026%	the only printed line containing the activity is the Advanced Materials segment (special steel, CITIC Metal trading, CITIC Resources, CITIC Pacific Energy), 43% of revenue, so neither a useful ceiling nor a floor exists
Avenue Supermarts India	Tobacco distribution, retail and supply > 25%	no split is published	0.0024%	n/a - no numerator printed and it is not stated which category would hold any tobacco; if it were FMCG the containing line (20.01%) would be <= 25%, but Foods (57.73%) cannot be excluded, so no bound is claimed
Tosoh Japan	Thermal coal > 5%	no split is published	0.0023%	no split - generation is mainly captive (own chemical plants); external power sales exist but are unquantified and not assigned to a segment
Hanwha Corporation South Korea	Thermal coal > 5%	no split is published	0.0022%	n/a - no numerator printed; the only segment that could hold coal sales (Trading and wholesale retails, 7.34%) exceeds 5% so gives no bound, and trading is outside the numerator anyway
Japan Airport Terminal Japan	Tobacco distribution, retail and supply > 25%	no split is published	0.0020%	the containing line (国際線売店売上, 35.3% of revenue) exceeds 25%, so no bound
Tsuruha Japan	Tobacco distribution, retail and supply > 25%	no split is published	0.0020%	tobacco not placed in any printed line; 雑貨 (26.0%) and 食品 (25.9%) each exceed 25%, so the all-lines test gives no bound
President Chain Store Taiwan	Tobacco distribution, retail and supply > 25%	no split is published	0.0019%	n/a - no numerator printed; the containing convenience-store segment is 62.08% of revenue (> 25%), so no bound
Cencosud Chile	Tobacco distribution, retail and supply > 25%	no split is published	0.0017%	n/a - no numerator printed; the containing Supermercados segment is 81.1% of revenue (> 25%), so no bound
Harbour Energy United Kingdom	Arctic drilling > 5%	no split is published	0.0017%	Norway segment also contains Skarv, Gjøa, Njord, Dvalin, Maria, Edvard Grieg, Snorre area etc.; no hub-level revenue
Grupo Carso Mexico	Tobacco distribution, retail and supply > 25%	no split is published	0.0016%	n/a - no numerator printed; it is not stated which retail line would hold tobacco. Department stores alone are 16.3% of income, but department stores + food & beverage (restaurants) are 26.4% (> 25%), so no line that certainly contains all possible tobacco is <= 25%
MOL Hungarian Oil Hungary	Tobacco distribution, retail and supply > 25%	no split is published	0.0015%	n/a - no numerator printed; the containing Consumer Services line is 28.5% of segment sales (39.6% of external sales), > 25%, so no bound
Sundrug Japan	Tobacco distribution, retail and supply > 25%	no split is published	0.0015%	no product split; both segment lines exceed 25%
Mitsubishi Materials Japan	Thermal coal > 5%	no split is published	0.0015%	equity-accounted: MUCC revenue is not the holder's revenue; consolidated numerator appears nil (no consolidated coal mining/sales or coal-fired power described)
Blue Zones Holdings Japan	Tobacco distribution, retail and supply > 25%	no split is published	0.0013%	tobacco not placed in any printed line; 生鮮食品 (33.3%) and 加工食品 (27.6%) exceed 25%, so the all-lines test gives no bound
E-Mart South Korea	Tobacco distribution, retail and supply > 25%	no split is published	0.0013%	no tobacco numerator printed; the containing retail segment is far above 25%
Sendas Distribuidora Brazil	Tobacco distribution, retail and supply > 25%	no split is published	0.0012%	n/a - no numerator printed; the only containing line is total revenue (single segment), so no bound
Grupo Cementos de Chihuahua Mexico	Thermal coal > 5%	no split is published	0.0012%	'Other' mixes coal with several non-coal products and is stated before intercompany eliminations (which include coal shipped to GCC's own cement plants)
DFI Retail Group Holdings Bermuda	Tobacco distribution, retail and supply > 25%	no split is published	0.0011%	the containing Convenience line is 2,342.0 / 8,868.9 = 26.4% (> 25%), so no bound; ready-to-eat (24% of Convenience sales, non-cigarette) caps Convenience cigarettes at ~20.1% of revenue, but Food-segment tobacco is not bounded
AG Anadolu Grubu Holding Turkey	Tobacco distribution, retail and supply > 25%	no split is published	0.0011%	n/a - no numerator printed; Migros retail sales are not split by category and AGHOL's own segment note was not retrieved, so no containing line <= 25% is available
Quinenco Chile	Tobacco distribution, retail and supply > 25%	no split is published	0.0010%	n/a - no numerator printed; the containing Enex line is 89.2% of industrial revenue (~57% even with banking revenue added), so no bound
Motor Oil Greece	Tobacco distribution, retail and supply > 25%	no split is published	0.0010%	n/a - no numerator printed; the only line that would contain shop goods ('Merchandise', which also holds traded fuels) is 32.6% of group sales (> 25%), so no bound
Jardine Cycle & Carriage Singapore	Thermal coal > 5%	no split is published	0.0010%	no split - the containing segment (37.7%) exceeds 5% so gives no bound; UT's printed coal line (Thermal and Metallurgical Coal Mining, Rp26.0tn) mixes met coal and third-party traded coal and is in a different document and currency; Pamapersada contract-mining revenue is service revenue (excluded)
Daicel Japan	Tobacco distribution, retail and supply > 25%	no split is published	0.0010%	the containing line (マテリアル事業, 31.27% of revenue) exceeds 25%, so no bound
Central Retail Thailand	Tobacco distribution, retail and supply > 25%	no split is published	0.0009%	n/a - no numerator printed; the containing Food segment is 40.5% of revenue (> 25%), so no bound
Grupo Comercial Chedraui Mexico	Tobacco distribution, retail and supply > 25%	no split is published	0.0008%	n/a - no numerator printed; both retail lines (Mexico 47%, USA 52%) exceed 25%, so no bound
China International Travel Service China	Tobacco distribution, retail and supply > 25%	no split is published	0.0007%	n/a - no numerator printed; the containing duty-free merchandise line is 72.9% of revenue (> 25%), so no bound
China Tourism Group Duty Free Corporation China	Tobacco distribution, retail and supply > 25%	no split is published	0.0006%	n/a - no numerator printed; the containing duty-free merchandise line is 72.9% of revenue (> 25%), so no bound
Alfamart Indonesia	Tobacco distribution, retail and supply > 25%	no split is published	0.0006%	no cigarette amount printed; revenue is split only Food 89,629,405 (70.72%) / Non-food 37,107,846 (29.28%) of 126,737,251 (Rp million), both above 25%, so whichever holds cigarettes gives no bound
SJVN India	Thermal coal > 5%	no split is published	0.0006%	the filed fiscal year (to 31 Mar 2025) predates coal generation, but Buxar Unit-1 (660 MW, coal) entered commercial operation on 14 Nov 2025, before the 31 Jan 2026 holding date; no filed full-year figure reflects the holding-date position
Ube Industries Japan	Thermal coal > 5%	no split is published	0.0006%	MUCC is equity-accounted, so its coal-sales and power revenue is not UBE revenue; UBE's own electric power supply business is unquantified inside Others (16.4%, no bound)
POSCO International South Korea	Thermal coal > 5%	no split is published	0.0005%	equity-accounted: associate revenue is not the holder's revenue (Mong Duong 2); coal trading/raw-material supply is not in the numerator; Narrabri stake accounting and revenue not disclosed
Lotte Shopping South Korea	Tobacco distribution, retail and supply > 25%	no split is published	0.0005%	no tobacco numerator printed; no containing line below 25% can be shown
Migros Ticaret Turkey	Tobacco distribution, retail and supply > 25%	no split is published	0.0005%	n/a - no numerator printed; the containing retail sales line is ~97% of gross domestic sales, so no bound
Izumi Japan	Tobacco distribution, retail and supply > 25%	no split is published	0.0005%	no product split; the retail segment (小売事業) is ~97% of revenue
Savola Group Saudi Arabia	Tobacco distribution, retail and supply > 25%	no split is published	0.0004%	n/a - no numerator printed; the containing retail (Panda) line is 44.3% of revenue (> 25%), so no bound
CP AXTRA Thailand	Tobacco distribution, retail and supply > 25%	no split is published	0.0004%	n/a - no numerator printed; the only containing line with a figure (Makro dry grocery 51.1% of wholesale sales, i.e. ~27.6% of group sale of goods) is above 25%, so no bound; Lotus's liquor-and-tobacco category has no share printed
Lotte South Korea	Tobacco distribution, retail and supply > 25%	no split is published	0.0004%	no tobacco numerator; the containing segment is 31.1% of revenue
Kumho Petrochemical South Korea	Thermal coal > 5%	no split is published	0.0003%	no split - the only printed line containing Energy (Energy + Specialty Chemicals + Others, 10.8%) exceeds 5% so gives no upper bound; Energy itself includes steam and gas/TDF/biomass-fired output

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%	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

228 of 1175 holdings — 40.49% of the extracted equity lines — carry a finding we map to a principle

The fund’s rule runs on FTSE Russell and MSCI data, the ESG sources its fund factsheet names; 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

11 holdings (1.2% of the scheme) are behind their own promise or have witnesses that disagree; 2 are ahead (0.2%). 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 →

36 more commitments in this report

Enter a work email for the full report on data as at 30 June 2026: every commitments with the determination behind it, the regulator, the date and a link to the source record.