Pension fund evidence — the register

Pension fund evidence report

The register — ten default arrangements

Two measures run through this report and they answer different questions. The holdings measures are our standard, applied identically to every fund, so any fund is comparable to any other. The commitment tests are each scheme’s own standard, and they differ. A breach count means nothing across funds without the threshold beside it.

What is in the fund

Adverse and excluded exposure on adjudicated determinations by named regulators. The same test for everybody.

What the scheme promised

Its own published exclusions, tested on its own wording and its own level. A different test for each scheme.

WHAT IS IN EACH FUND, AND HOW IT COMPARES

Both measures, side by side

Each shaded column is drawn against its own range, not against 100% — adverse exposure runs 26.7% to 48.0% across the register, and a column scaled to 100 would be uniformly pale and distinguish nothing.

Scheme	Seen	Adverse	Excluded	Screened for activity	Its own threshold	Against that threshold
Royal London Governed Range	74.8%53% of RLP Global Managed publishes look-through; the rest is blended pools Royal London does not split — a disclosure limit	26.7%	9.9%	14.4%of the fund	≥60% coal	1 above threshold 22 tests unanswered
AJ Bell Pension Builder	83.2%	34.5%	14.3%	12.0%of the fund	— none published	NOTHING TO TEST promised nothing about it
Standard Life (PUTM ACS)	83.1%	41.1%	16.8%	8.7%of the fund	>5% oil sands >5% coal >1% tobacco >25% tobacco	none above threshold 17 tests unanswered
Aegon Workplace Default	88.4%	41.7%	17.0%	7.1%of the fund	>5% oil sands >5% coal >0% tobacco	none above threshold 20 tests unanswered
Fidelity FutureWise 2070	82.6%	48.0%	15.0%	5.1%of the fund	>5% oil sands >5% coal	none above threshold 7 tests unanswered
Atlas / SEI Master Trust	86.7%	33.8%	13.6%	4.7%of the fund	>10% coal	none above threshold 14 tests unanswered
Mercer SmartPath §12	85.5%	35.8%	12.5%	4.2%of the fund	>1% oil sands >5% oil sands ≥5% oil sands any0% coal >1% coal ≥5% coal >0% tobacco any0% tobacco >5% tobacco >50% tobacco	NOTHING TO TEST published a level this report cannot run
Mercer SmartPath §12b	86.0%	35.8%	12.7%	3.9%of the fund	>1% oil sands >5% oil sands ≥5% oil sands any0% coal >1% coal ≥5% coal >0% tobacco any0% tobacco >5% tobacco >50% tobacco	NOTHING TO TEST published a level this report cannot run
Smart Pension Default	83.8%	42.0%	16.9%	1.3%of the fund	>20% oil sands >20% coal	NOTHING TO TEST published a level this report cannot run
Scottish Widows Growth Fund	87.3%	41.6%	14.2%	4.7%of the fund	≥5% oil sands ≥5% coal >10% tobacco	none above threshold 10 tests unanswered

Rows below 50% seen are dimmed and are not ranked against the rows above. Their adverse figure rests on less than half the fund, so a low number can mean opacity rather than virtue.

THE FINDING THAT NEEDS BOTH COLUMNS

A breach count of zero is not the same as nothing to find

AJ Bell Pension Builder screens at 11.98% of the fund and publishes no level this report can test. Its breach count is zero, and that zero says nothing about the fund: the scheme promised nothing measurable about most of what it holds.

Royal London Governed Range is the mirror image. It screens at 14.42% and it is the only scheme in the register with a breach — 1 holding at 0.0019% of the fund against its own published level. Every other row shows nought, and for two different reasons: 5 published a level and nothing in the book crossed it, and 4 published no level this report could run. One breach against a published standard is a more informative result than 4 zeros that were never tests.

Neither column is a verdict on its own. A fund can hold little and have promised nothing; a fund can promise a great deal and breach once. The report shows both and leaves the reading to the trustee, which is the same reason it publishes no score.

PER SCHEME

What each scheme promised, and whether it kept it

Each scheme opens to two linked pages: the commitments it published, with every threshold verbatim, the band it sits in and whether it can be tested at all; and the holdings, tested against those commitments, with the determination and source behind every row. By block opens the same figures one level down: each sub-fund with its weight, its own rule and its own result.

Scheme	Its own threshold	Reports
Royal London Governed Range	≥60% coal	Commitments → Holdings evidence → By block → Is it moving? →
AJ Bell Pension Builder	— none published	no commitments workbook By block → Is it moving? →
Standard Life (PUTM ACS)	>5% oil sands >5% coal >1% tobacco >25% tobacco	Commitments → Holdings evidence → By block → Is it moving? →
Aegon Workplace Default	>5% oil sands >5% coal >0% tobacco	Commitments → Holdings evidence → By block → Is it moving? →
Fidelity FutureWise 2070	>5% oil sands >5% coal	Commitments → Holdings evidence → By block → Is it moving? →
Atlas / SEI Master Trust	>10% coal	Commitments → Holdings evidence → By block → Is it moving? →
Mercer SmartPath §12	>1% oil sands >5% oil sands ≥5% oil sands any0% coal >1% coal ≥5% coal >0% tobacco any0% tobacco >5% tobacco >50% tobacco	Commitments → Holdings evidence → By block → Is it moving? →
Mercer SmartPath §12b	>1% oil sands >5% oil sands ≥5% oil sands any0% coal >1% coal ≥5% coal >0% tobacco any0% tobacco >5% tobacco >50% tobacco	Commitments → Holdings evidence → By block → Is it moving? →
Smart Pension Default	>20% oil sands >20% coal	Commitments → Holdings evidence → By block → Is it moving? →
Scottish Widows Growth Fund	≥5% oil sands ≥5% coal >10% tobacco	Commitments → Holdings evidence → By block → Is it moving? →

A level is only as strict as the disclosure it can be run against. Where a company does not publish the split, the commitment cannot be run against it — and unmeasured is not clean. Every page that quotes a breach count states the count of tests that could not be answered beside it.

Every published threshold, compared →

Evidence snapshot C:\ESGTools\scoring-v2\snapshots\2026-10-12T1501-nightly · identity resolution 2026-09-30-sl-adopt · activity revenue read from activity_revenue.csv · commitments read from each scheme’s own published documents into fund_view/commitments/ · built by fund_view/register_report.py. Every figure on this page is read from one of those; none is typed in.