Royal London Governed Range

Commitments report

Royal London Governed Range — 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	“manufacture of cluster munitions, anti-personnel landmines and chemical and biological weapons” RLMIS segregated mandates and RLAM-managed pooled funds · p.2	any manufacture	NOT YET TESTED Waiting on: the data the rule runs on
Mechanism exclusion Scope as written RLMIS segregated mandates and RLAM-managed pooled funds Threshold any manufacture Source document p.2 →
▸ Thermal coal	“2 billion tonnes or more of thermal coal reserves globally” RLMIS segregated mandates and RLAM-managed pooled funds · p.3	>=2bn tonnes reserves	NOT YET TESTED Waiting on: the data the rule runs on
Mechanism exclusion Scope as written RLMIS segregated mandates and RLAM-managed pooled funds Threshold >=2bn tonnes reserves Source document p.3 →
▸ Thermal coal	“60% or more of their revenues from thermal coal mining” RLMIS segregated mandates and RLAM-managed pooled funds · p.3	>=60% revenue	NOT YET TESTED Waiting on: the data the rule runs on
Mechanism exclusion Scope as written RLMIS segregated mandates and RLAM-managed pooled funds Threshold >=60% revenue Source document p.3 →

Layer 2 · the underlying funds inside the default

3 rules

Standard	Commitment	Share of equities	Result
▸ Controversial weapons	“manufacture of cluster munitions, anti-personnel landmines and chemical and biological weapons” US Equity Tilt; Global Equity Diversified; Emerging Markets Equity Tilt · p.2	30.6%	TESTED, SOME HOLDINGS NOT SETTLED At any manufacture: Rule: any manufacture of cluster munitions, anti-personnel landmines, chemical or biological weapons (a named list: nuclear-only involvement is outside it). In the three confirmed sleeves (the 53% of RLP Global Managed with published look-through): 0 over threshold of 1,356 issuers in scope; 5 answered from existing register rows, nothing collected; 1,260 screen-negative (558 on Scottish Widows' / Standard Life's review of the same company; a screen, not a document); 91 candidates not collected (3.86%; register-only run). In the six RLAM funds that sit inside blended pools whose split Royal London does not publish (1,255 issuers; RLAM pooled funds, so inside the rule's scope, but with no weight in the pension - a disclosure limit, not a gap in the test): 0 over threshold; 12 answered from register rows, 1,171 screen-negative, 72 candidates not collected. Holdings 31 Aug 2025; rulebook December 2025, later than the holdings, so nothing here is called a breach.
Mechanism commitment Scope as written US Equity Tilt; Global Equity Diversified; Emerging Markets Equity Tilt Threshold any manufacture Source document p.2 → What the test found. Rule: any manufacture of cluster munitions, anti-personnel landmines, chemical or biological weapons (a named list: nuclear-only involvement is outside it). In the three confirmed sleeves (the 53% of RLP Global Managed with published look-through): 0 over threshold of 1,356 issuers in scope; 5 answered from existing register rows, nothing collected; 1,260 screen-negative (558 on Scottish Widows' / Standard Life's review of the same company; a screen, not a document); 91 candidates not collected (3.86%; register-only run). In the six RLAM funds that sit inside blended pools whose split Royal London does not publish (1,255 issuers; RLAM pooled funds, so inside the rule's scope, but with no weight in the pension - a disclosure limit, not a gap in the test): 0 over threshold; 12 answered from register rows, 1,171 screen-negative, 72 candidates not collected. Holdings 31 Aug 2025; rulebook December 2025, later than the holdings, so nothing here is called a breach.
▸ Thermal coal	“2 billion tonnes or more of thermal coal reserves globally” US Equity Tilt; Global Equity Diversified; Emerging Markets Equity Tilt · p.3	30.6%	NOT YET TESTED '2 billion tonnes or more of thermal coal reserves globally': a reserves test in tonnes, not a revenue test. The register holds revenue shares, not reserve tonnages, and no reserves source is wired. Not forced into a revenue test; no verdict is derived
Mechanism commitment Scope as written US Equity Tilt; Global Equity Diversified; Emerging Markets Equity Tilt Threshold >=2bn tonnes reserves Source document p.3 → Not yet tested, and not forced into a test it does not ask for. '2 billion tonnes or more of thermal coal reserves globally': a reserves test in tonnes, not a revenue test. The register holds revenue shares, not reserve tonnages, and no reserves source is wired. Not forced into a revenue test; no verdict is derived A rule outside this report’s scope is never shown as met, and never as a pass.
▸ Thermal coal	“60% or more of their revenues from thermal coal mining” US Equity Tilt; Global Equity Diversified; Emerging Markets Equity Tilt · p.3	30.6%	TESTED, SOME HOLDINGS DISCLOSE NO FIGURE At >=60% revenue: Rule: 60% or more of revenue from thermal coal mining. In the three confirmed sleeves (the 53% of RLP Global Managed with published look-through): 0 over threshold of 1,356 issuers in scope; 2 not disclosed (0.38%); 36 answered from existing register rows, nothing collected; 1,193 screen-negative (531 on Scottish Widows' / Standard Life's review of the same company; a screen, not a document); 127 candidates not collected (4.42%; register-only run). In the six RLAM funds that sit inside blended pools whose split Royal London does not publish (1,255 issuers; RLAM pooled funds, so inside the rule's scope, but with no weight in the pension - a disclosure limit, not a gap in the test): 1 over threshold: Yancoal Australia (73.05% on the company's own figures, Asia Pacific ex Japan Tilt); 20 answered from register rows, 1,159 screen-negative, 76 candidates not collected. The loosest coal level in the set (Mercer >1%, Scottish Widows ≥5%, Standard Life >5%, Mercer ≥5%, Aegon >5%, Fidelity >5%, Atlas / SEI >10%): almost nothing can breach it, so a near-empty result is the rule's weakness, not a clean book. Holdings 31 Aug 2025; rulebook December 2025, later than the holdings, so nothing here is called a breach.
Mechanism commitment Scope as written US Equity Tilt; Global Equity Diversified; Emerging Markets Equity Tilt Threshold >=60% revenue Source document p.3 → What the test found. Rule: 60% or more of revenue from thermal coal mining. In the three confirmed sleeves (the 53% of RLP Global Managed with published look-through): 0 over threshold of 1,356 issuers in scope; 2 not disclosed (0.38%); 36 answered from existing register rows, nothing collected; 1,193 screen-negative (531 on Scottish Widows' / Standard Life's review of the same company; a screen, not a document); 127 candidates not collected (4.42%; register-only run). In the six RLAM funds that sit inside blended pools whose split Royal London does not publish (1,255 issuers; RLAM pooled funds, so inside the rule's scope, but with no weight in the pension - a disclosure limit, not a gap in the test): 1 over threshold: Yancoal Australia (73.05% on the company's own figures, Asia Pacific ex Japan Tilt); 20 answered from register rows, 1,159 screen-negative, 76 candidates not collected. The loosest coal level in the set (Mercer >1%, Scottish Widows ≥5%, Standard Life >5%, Mercer ≥5%, Aegon >5%, Fidelity >5%, Atlas / SEI >10%): almost nothing can breach it, so a near-empty result is the rule's weakness, not a clean book. Holdings 31 Aug 2025; rulebook December 2025, later than the holdings, so nothing here is called a breach.

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%	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%	this scheme — 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

9 holdings (2.2% of the scheme) are behind their own promise or have witnesses that disagree; 2 are ahead (0.0%). 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 →