Atlas / SEI Master Trust — transition evidence

Resolver 2026-09-30-sl-adopt · verdicts 2026-10-12-ship · carbon feed 2026-09-07-metrics-rev2 · Licence-restricted verdicts withheld

Transition evidence

Where this book has a material gap

Alternatives are ranked on emissions trajectory and evidence agreement only. This is not investment advice and says nothing about returns, valuation or suitability.

4 holdings (0.82% of the scheme) are behind their own promise or have witnesses that disagree, ranked by the carbon at stake in this book (weight × verified, else observed, tonnes). 0 carry a same-sector alternative; 3 have none in the assessed set, which is recorded, not padded.

Equinor ASAWitnesses differ weight 0.35% · 8.81 Mt verified
Verified 2025: 8.81 Mt at 21 installations. Observed at the matched installations: 0.30 Mt (verified there: 0.23 Mt). Observed above verified beyond band (±29%) in 2023 (+43%), 2024 (+262%) and 2025 (+30%). The two independent sources differ; this is not a finding about the company.
Evidence
- EU ETS installations: NO_206862, NO_209936, NO_213640, NO_72, NO_75, NO_76, NO_77, NO_79, NO_80, NO_81, NO_82, NO_83, NO_84, NO_85, NO_86, NO_87, NO_88, NO_89, NO_91, NO_92, NO_93, ['NO_93']
- Climate TRACE sources: ['45257198']
- Climate TRACE fleet: C:\~\Blockfilm\.claude\worktrees\camd-calibration\ESGTools\fetchers\snapshots\climate_trace\2026-10-12-ship\trend_climate_trace.csv; company_id 220546
- Company filing (2024): annual_financial_report_esef p.118 — “I 2024 var 65% av CO2 utslippene (scope 1) fra egen virksomhet regulert gjennom kvotehandel.” sha256 ba35ec722499
- Promise: Company filing p.108 — “Equinor en ambisjon om å redusere netto klimagassutslipp (scope 1 og 2) med 50% innen 2030, sammenlignet med 2015.”
Alternative
Equinor ASA: verified and observed differ beyond the band. No same-sector alternative in the assessed set passes the rule.
Shell plcWitnesses differ weight 0.22% · 8.74 Mt verified
Verified 2025: 8.74 Mt at 5 installations. Observed at the matched installations: 4.45 Mt (verified there: 3.34 Mt). Company filed (ETS scope): 37.3 Mt (ESEF AR p.370), on a wider perimeter than the mapped holders, not compared. Observed above verified beyond band (±35%) in 2023 (+43%) and 2024 (+62%). The two independent sources differ; this is not a finding about the company.
Evidence
- EU ETS installations: 'NL_383'], DE_31, DE_32, NL_205868, NL_383, NL_99, ['DE_32',
- Climate TRACE sources: '3143897'], ['18648367',
- Climate TRACE fleet: C:\~\Blockfilm\.claude\worktrees\camd-calibration\ESGTools\fetchers\snapshots\climate_trace\2026-10-12-ship\trend_climate_trace.csv; company_id 12384
- Company filing (2025): annual_financial_report_esef p.370 — “The percentage of Scope 1 GHG emissions from assets falling under regulated emission trading schemes was 54% on an ESRS reporting boundary” sha256 3403693753ac
- Promise: Company filing p.98 — “reduce Scope 1 and 2 absolute emissions from assets and activities under our operational control (including divestments) by 50% by 2030 compared with the 2016 baseline, on a net basis”
Alternative
No alternative sought: the observed perimeter is too thin to speak for the company.
Eni S.p.A.Behind weight 0.15% · 10.13 Mt verified
Promised −13.9% a year (2018→2025, −65% Scope 1+2, filing p.160). Observed −2.3% a year 2021–2025, verified. Behind by 11.6 points (tolerance ±6.1 points).
Evidence
- EU ETS installations: 'IT_179',, 'IT_180',, 'IT_202272',, 'IT_355',, 'IT_512',, 'IT_517',, 'IT_541'], IT_124, IT_179, IT_180, IT_202272, IT_355, IT_512, IT_517, IT_541, IT_542, IT_620, IT_621, IT_627, IT_628, IT_630, ['IT_124',
- Climate TRACE sources: '25453044',, '3143965',, '3143967',, '40693183',, '447388',, '447433',, '449268',, '450374'], ['1753644',
- Climate TRACE fleet: C:\~\Blockfilm\.claude\worktrees\camd-calibration\ESGTools\fetchers\snapshots\climate_trace\2026-10-12-ship\trend_climate_trace.csv; company_id 61616
- Company filing (2025): annual_financial_report_esef p.355 — “Nell’esercizio 2025, le emissioni di anidride carbonica delle installazioni Eni sono risultate, complessivamente, superiori rispetto ai permessi assegnati. A fronte di 16,4 milioni di tonnellate di a” sha256 c293f0ac1b34
- Promise: Company filing p.160 — “Inoltre, nel 2025, il target di raggiungimento del -65% rispetto al 2018 è stato superato con una riduzione di circa il -68%.”
Alternative
Eni S.p.A.: behind by 11.6 points (verified). No same-sector alternative in the assessed set passes the rule.
Endesa S.A.Witnesses differ weight 0.09% · 7.30 Mt verified
Verified 2025: 7.30 Mt at 18 installations. Observed at the matched installations: 2.08 Mt (verified there: 3.03 Mt). Observed below verified beyond band (±25%) in 2024 (−31%) and 2025 (−31%). The two independent sources differ; this is not a finding about the company.
Evidence
- EU ETS installations: 'ES_223',, 'ES_225',, 'ES_226',, 'ES_227',, 'ES_719'], ES_1508, ES_222, ES_223, ES_224, ES_225, ES_226, ES_227, ES_228, ES_229, ES_431, ES_46, ES_47, ES_526, ES_719, ES_90008, ES_90009, ES_90047, ES_90048, ['ES_1508',
- Climate TRACE sources: '447988',, '449601',, '449604',, '449605',, '449608'], ['447987',
- Company filing (2024): annual_financial_report_esef p.259 — “Porcentaje de Emisiones de Gases de Efecto Invernadero (GEI) de Alcance 1 procedentes de Regímenes regulados de Comercio de Derechos de Emisión (%) 99,0 % 99,0 % 99,0 % 0,00 % — — —” sha256 6a1829def1d6
Alternative
Endesa S.A.: verified and observed differ beyond the band. No same-sector alternative in the assessed set passes the rule.

Ahead in this book

Alternatives are ranked on emissions trajectory and evidence agreement only. This is not investment advice and says nothing about returns, valuation or suitability.

No holding in this scheme is ahead of its own promise on the evidence held.

Coverage

Of this scheme's Scope 1 exposure, 14% verified, 15% independent, 7% assured and 64% self-filed. The shares are REVENUE-weighted: each holding counts as its weight × the company's Scope 1 ÷ its revenue, the same decomposition as the carbon-intensity figure, and they are never added together. 53 held companies have a Scope 1 figure but no revenue figure, so they are outside this measure on both sides: by absolute tonnes they carry 6% of this scheme's Scope 1. With a sector-median revenue imputed for the companies that have none: 17% verified, 16% independent, 7% assured and 60% self-filed. Weighted by absolute tonnes instead (which lets the largest emitters dominate): 19% verified, 5% independent, 16% assured and 60% self-filed. Not counted anywhere yet: 45 Climate TRACE fleets (398 Mt) that no company record joins and that wait for a person's review, the largest China Resources Power Holdings Co Ltd at 118 Mt; if any of them is held, its Climate TRACE tonnage is missing from the independent share above.

Two verdicts per holding, independent of each other, neither a score. Agreement: do the witnesses agree on what happened? Pace: is it moving at its own promised speed? They sit beside the band and never in it. Shares are of the whole scheme by weight; 13.4% did not resolve to a company and is counted as not assessed.

Agreement

Agree	0.0%
Disputed	0.0%
Witnesses differ	0.7%
Partial	1.2%
Not assessed	98.1%

Pace

On track	1.0%
Behind	0.2%
Ahead	0.0%
Not assessed	98.8%

0.8% of the scheme carries a Pace verdict resting on a licence-restricted promise; it is shown here as not assessed.

Perimeter: Agreement rests on EU ETS installations only, so every Agreement state here is EU-only observation. Of the holdings with any state, 8 (1.9% of the scheme) rest on EU-only observation and 0 (0.0%) on Climate TRACE power plants only.

Disputed means the sources disagree, never misreported. Witnesses differ means the two independent sources disagree with each other and is not a finding about the company. Behind means slower than the company's own promise and says nothing about 1.5°C. No temperature, no alignment verdict, no number out of 100. Rule: climate/DECISION-TRANSITION-STATES.md.