based on specific criteria (e.g. revenue thresholds) - Phase-out: setting a timeline to phase out financing for a specific sector or category of clients - Enhanced screening: performing additional checks (e.g., enhanced due diligence) to inform risk appetite and governance, without committing to a financing outcome We distinguish phase-out commitments from portfolio reduction targets: a commitment to exit any type of fossil fuel financing, including commitments to exit with residual exposure, is in scope, but a target to cut financing or financed emissions without an exit is not. This is true even if such targets represent interim milestones within an exit strategy. ### Commitment fields For each commitment, we extract a defined set of fields that determine its scope and strength. This standardizes the explicit and implicit applicability rules that most commonly determine a policy's breadth and effectiveness. | Structured fields | What they capture | | :---------------- | :------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | | Sector |

Theme: coal or oil & gas
Sub-type: thermal or metallurgical coal; shale, oil sands, etc.
Value chain: upstream, midstream, or downstream
Asset stage: new and/or existing assets

| | Geography |

Scope: global or limited to named regions or countries

| | Counterparty |

Entity: borrower or group (including parent and subsidiaries)
Relationship stage: new and/or existing clients

| | Product |

Financing type: project finance or corporate finance
Capital markets: facilitation included or not
Transaction stage: new and/or existing transactions (e.g., refinancing)

| | Timing |

Effective date: immediate or deferred

| **Triggers** Commitments to not fund fossil fuels are often based on threshold values defining what constitutes a fossil fuel company or project. To capture this, we record a number of composite fields: - quantitative triggers: numeric inequalities specifying a threshold (\>25% of revenue from coal) - qualitative triggers: written descriptions of the threshold (“‘significant’ revenue from coal”) - timeframe: when a measurement is specified to be taken (“revenues based on the most recent fiscal year”) **Loopholes** Carve-outs to commitments often prove too varied to standardise. As a result, we also capture a less-standardized “loophole” field with two subfields - Exceptions: a list of written exceptions to the policy - Weaknesses: descriptions of how loopholes might undermine a policy’s effectiveness. Keeping loopholes separate from the structured dimensions reflects a deliberate choice: the dimensions standardise the limits that recur across banks, while loopholes capture bespoke conditions that otherwise would not fit a fixed field. ## Synthesis & verification process On a high level, the process of cataloging commitments is very similar to how linguists diagram sentence structure, but applied to a text as a whole. While there is ambiguity in commitments, as there often is in language, there is still useful information to be extracted and synthesised. Policy synthesis is deri