Smart Pension Default — commitments

Commitments report

Smart Pension Default — can what it promised be tested?

8 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

1not testable as written

0need data this report does not carry

4tested against holdings

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

4 commitments

Standard	What the scheme wrote	Threshold	Result
▸ Other	“net zero default growth by 2040” default growth fund · p.web	net zero by 2040	NO INTERIM MEASURE
Mechanism target Scope as written default growth fund Threshold net zero by 2040 Source document p.web → 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.
▸ Other	“75% reduction from 2019 by 2030” default growth fund · p.web	75% by 2030	NOT YET TESTED Waiting on: the data the rule runs on
Mechanism target Scope as written default growth fund Threshold 75% by 2030 Source document p.web →
▸ Thermal coal	“more than 20% of their revenues from thermal coal” historical LGIM fund in 2023 default · p.historical page	>20% revenue	TESTED, SOME HOLDINGS NOT SETTLED At >20% revenue: Rule: more than 20% of revenue from thermal coal (trustee wording of 2023 for the LGIM fund then in the default, read on today's default fund). 0 over threshold of 1,317 issuers in scope; 12 answered from existing register rows, nothing collected; 1,219 screen-negative (662 on Scottish Widows' / Standard Life's review of the same company; a screen, not a document); 86 candidates not collected (1.83%; register-only run). Other schemes' coal levels: Mercer >1%, Scottish Widows ≥5%, Standard Life >5%, Mercer ≥5%, Aegon >5%, Fidelity >5%, Atlas / SEI >10%, Royal London ≥60%. Holdings 28 Aug 2026.
Mechanism exclusion Scope as written historical LGIM fund in 2023 default Threshold >20% revenue Source document p.historical page → What the test found. Rule: more than 20% of revenue from thermal coal (trustee wording of 2023 for the LGIM fund then in the default, read on today's default fund). 0 over threshold of 1,317 issuers in scope; 12 answered from existing register rows, nothing collected; 1,219 screen-negative (662 on Scottish Widows' / Standard Life's review of the same company; a screen, not a document); 86 candidates not collected (1.83%; register-only run). Other schemes' coal levels: Mercer >1%, Scottish Widows ≥5%, Standard Life >5%, Mercer ≥5%, Aegon >5%, Fidelity >5%, Atlas / SEI >10%, Royal London ≥60%. Holdings 28 Aug 2026.
▸ Oil sands	“more than 20% of their revenues from oil sands” historical LGIM fund in 2023 default · p.historical page	>20% revenue	TESTED, SOME HOLDINGS NOT SETTLED At >20% revenue: Rule: more than 20% of revenue from oil sands (trustee wording of 2023 for the LGIM fund then in the default, read on today's default fund). 0 over threshold of 1,317 issuers in scope; 5 answered from existing register rows, nothing collected; 1,289 screen-negative (669 on Scottish Widows' / Standard Life's review of the same company; a screen, not a document); 23 candidates not collected (0.50%; register-only run). Holdings 28 Aug 2026.
Mechanism exclusion Scope as written historical LGIM fund in 2023 default Threshold >20% revenue Source document p.historical page → What the test found. Rule: more than 20% of revenue from oil sands (trustee wording of 2023 for the LGIM fund then in the default, read on today's default fund). 0 over threshold of 1,317 issuers in scope; 5 answered from existing register rows, nothing collected; 1,289 screen-negative (669 on Scottish Widows' / Standard Life's review of the same company; a screen, not a document); 23 candidates not collected (0.50%; register-only run). Holdings 28 Aug 2026.

Layer 2 · the underlying funds inside the default

2 rules

Standard	Commitment	Share of equities	Result
▸ UN Global Compact	“including only companies operating in accordance with market standards for responsible business conduct” Smart Pension Net Zero Pathway Custom Equity Index Fund · p.Overview	50.9%	TWO MEASURES — 152 HOLDINGS CARRY A FINDING WE MAP TO IT
Mechanism commitment Scope as written Smart Pension Net Zero Pathway Custom Equity Index Fund Threshold norms-based research Source document p.Overview → Not yet tested. A number, a direction and a unit. The row is waiting on issuer norms status and dated official index constituents. A rule outside this report’s scope is never shown as met.
▸ Controversial weapons	“controversial weapons” Smart Pension Net Zero Pathway Custom Equity Index Fund · p.Overview	50.9%	TESTED, SOME HOLDINGS NOT SETTLED At index exclusion per methodology: Rule: controversial weapons, excluded by the index methodology (the term is not defined). 0 over threshold of 1,317 issuers in scope; 0 answered from existing register rows, nothing collected; 1,223 screen-negative (672 on Scottish Widows' / Standard Life's review of the same company; a screen, not a document); 94 candidates not collected (2.49%; register-only run). Holdings 28 Aug 2026.
Mechanism commitment Scope as written Smart Pension Net Zero Pathway Custom Equity Index Fund Threshold index exclusion per methodology Source document p.Overview → What the test found. Rule: controversial weapons, excluded by the index methodology (the term is not defined). 0 over threshold of 1,317 issuers in scope; 0 answered from existing register rows, nothing collected; 1,223 screen-negative (672 on Scottish Widows' / Standard Life's review of the same company; a screen, not a document); 94 candidates not collected (2.49%; register-only run). Holdings 28 Aug 2026.

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.

Coverage of the default arrangement

Which parts of the equity allocation a published rule reaches

Part of the arrangement	Share of equities	Status
AMX UCITS CCF DWS Global Low Carbon Stewardship Fund	30.2%	DOCUMENTS NOT RETRIEVED exact AMX supplement, SFDR disclosure and benchmark mapping
Mirova Global Green Bond; Clearlake Dual Credit; Octopus Energy Transition	19.0%	OUTSIDE EQUITY SCOPE none

30.2% of the listed-equity allocation sits in funds whose documents were not retrievable from the scheme’s published literature. That share is reported as unread rather than assumed either way — a screen we have not seen is never counted as absent, and never counted as present.

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%	this scheme — 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

152 of 833 holdings — 41.48% 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

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