Scottish Widows Growth Fund

Commitment · Scottish Widows Growth Fund

Thermal coal

5–19%

“So, in our mandated funds, our standard is not to invest in companies where 5% or more of their revenue is derived from thermal coal or tar sand extraction*.”

All Scottish Widows mandated funds, including the Growth Fund's index sleeves. The 2025 version of the Exclusions Standard could not be retrieved; tested against the current Standard (60307 07/26), which post-dates the May/June 2025 holdings. · read into scottish_widows_commitments.xlsx, sheet Commitments

What this level catches. written on EXTRACTION, so a generator's, hauler's or supplier's coal revenue does not test it The level is a choice inside a gap: 5% falls in the 10-point interval between 3.04% and 13.48% — no company in the register sits between them, so any level in that interval catches exactly the same 8 companies.

8of 10 companies with a figure sit at or above this level

4of those are inside this commitment’s wording — the rest carry a figure that answers a different question

0of those are held by this fund

10of 31 commitment tests on this fund could not be answered

Where ≥5% sits

Every extracted coal figure in the register

China Coal77%Yancoal73%Yankuang66%China Shenhua62%Whitehaven36%RWE20%Orica14%CSX13%BHP3.04%Sasol0.08%

≥5% threshold

nothing lives here — a 10-point gap

Bars in red are caught by this commitment. Bars in grey are outside its wording — the figure is real, but it does not answer the question the wording asks. The level and the wording are two separate filters and a company has to fail both to be excluded.

The test, company by company

Applied to every company with an extracted figure

Company	Revenue share	What the figure covers	Against this commitment	Why
CHINA COAL ENERGY CO	76.67%	value chain	OUTSIDE THE WORDING	value chain — the commitment is written on extraction Coal segment external revenue 113,509,802 of group total revenue 148,056,698 RMB'000. This is ALL coal - thermal, coking and proprietary trading coal together - because the audited segment note does not split them. On a self-produced thermal-coal-only reading the figure is materially lower (see note).
YANCOAL AUSTRALIA LTD	73.16%	extraction	ABOVE THE THRESHOLD	73.16% against a 5% threshold thermal coal sales of 32.0 Mt at an average realised price of A$136/t, giving A$4,352m, over revenue of A$5,949m
YANKUANG ENERGY GROUP CO	66.50%	extraction	ABOVE THE THRESHOLD	66.50% against a 5% threshold the Coal mining segment's external revenue 88,666,141 RMB'000 over external revenue 133,340,597 RMB'000 - all coal, NOT split by coal type
CHINA SHENHUA ENERGY CO LTD	62.01%	extraction	ABOVE THE THRESHOLD	62.01% against a 5% threshold the Coal segment's revenue from external customers 182,874 RMBm over revenue from external customers 294,916 RMBm
WHITEHAVEN COAL LIMITED	36.00%	extraction	ABOVE THE THRESHOLD	36.00% against a 5% threshold thermal coal sales as a percentage of revenues from coal sales of $5,832m, as the company states it
RWE AKTIENGESELLSCHAFT	20.00%	power generation	OUTSIDE THE WORDING	power generation — the commitment is written on extraction RWE's own published KPI: the portion of Group revenue related to coal-fired power generation and other coal products, measured against NET revenue (external revenue of 17,628 EURm, excluding natural gas and electricity tax)
ORICA LTD	14.00%	value chain	OUTSIDE THE WORDING	value chain — the commitment is written on extraction revenue from thermal coal customers as a percentage of external sales excluding Digital Solutions, as the company states it
CSX CORP	13.48%	value chain	OUTSIDE THE WORDING	value chain — the commitment is written on extraction coal freight revenue 1,900 $m over total revenue 14,092 $m - revenue from HAULING coal, not from mining or burning it
BHP GROUP LTDheld	3.04%	extraction	BELOW THE THRESHOLD	3.04% against a 5% threshold Energy coal product revenue 1,786 $m over group total revenue 58,760 $m
SASOL LTD	0.08%	extraction	BELOW THE THRESHOLD	0.08% against a 5% threshold external coal turnover 210 Rm over total external turnover 272,118 Rm

What could not be tested

10 of 31 commitment tests

10 — the company does not publish the split. A figure does not exist in its own reporting, so this commitment cannot be run against it. Not a pass.

A level is only as strict as the disclosure it can be run against. The remaining 10 are unmeasured rather than clean, and the report says so wherever this figure appears.

← 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.