d for such expansion," we record this as two commitments: one for upstream oil & gas, and one for midstream oil & gas. ### Scope Presently, we limit the scope of commitments we catalog to those related to coal, oil, and gas financing. A bank's asset management, wealth management, and insurance activities are out of scope, as are commitments on other themes (e.g., human rights, biodiversity), unless they explicitly relate to coal, oil, or gas. We cover three types of commitments: - Restriction: outright exclusion or conditioning financing 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 struc