Green Bonds Without

Greenwashing
February 17, 2022
By Thomas G. Walton

This post is dedicated to  Steve Hoey  (1962-2022)

            Global leaders must act together in establishing

universal regulations to govern the green bond market if
green bonds are to be used efficiently in the fight against
climate change. The profound gravity of this threat merits a
true global response. As such, the ethical responsibility of the
financial sector to act against climate change has grown
apparent in recent years. 

            Climate Finance (or “CliFin”) refers to any financial

service, instrument, vehicle, or regulation designed to
mitigate, or adapt to, the effects of climate change. One
example of CliFin is the green bond. A green bond is similar to
a regular bond in that it provides its issuer with funding
through the same mechanism; however, a green bond differs
from a regular bond in that any funds generated through
green bonds are specifically earmarked for projects aiming to
mitigate, or adapt to, the effects of climate change. Thus, the
purpose of green bonds is to provide investors with an easy
and low-risk means to invest in an environmentally conscious
way. 

            Unfortunately, practical limitations have decreased the

effectiveness of green bonds in the fight against climate
change. A lack of global standardization in definitions and
measurements has led to some issuers of green
bonds “greenwashing.” Greenwashing, in this context, is when
an issuer of a green bond exaggerates the positive
environmental impact of a project in an effort to secure
funding from environmentally conscious investors.
Greenwashing is at best misleading if not outright dishonest;
and yet, the practice is difficult to prevent as there is no
international regulation to determine what qualifies as a
green bond. For investors, greenwashing decreases trust in
the green bond market, and thus acts as a disincentive to buy
green bonds. This, in turn, negatively impacts sale of green
bonds not greenwashed. With global cooperation the
necessary regulations could be introduced to eliminate
greenwashing and amplify trust in the green bond market.
Green bonds are a good first step towards facilitating
environmentally conscious investing, but in order to
encourage more people to invest in green bonds it is essential
an international organization clearly define and enforce
eligibility criteria for projects funded by green bonds and
thereby avoid the problem of greenwashing.

A Brief History of Green Bonds

            Money secured by green bonds is meant to fund
projects aiming to mitigate, or adapt to, the effects of climate
change. The World Bank claims credit for issuing the first
green bond in November 2008 in response to a group of
Swedish pension funds looking to invest in projects that would
help mitigate climate change.  The European Investment
[1]

Bank, however, issued its Climate Awareness Bond (CAB) first,

in 2007.  Shortly after, other multilateral development banks
[2]

(MDBs) helped expand the market for green bonds. For

several years the market was dominated by MDBs, until 2013
when green bonds issued by corporate issuers and
government-backed entities saturated the market.  As the
[3]

number and types of issuers expanded, so did the variety of

projects funded by green bonds. Where MDBs had
predominantly focused on green infrastructure, new issuers
sought funding for energy, climate change adaptation, water,
waste, buildings, and transport. This transition saw the green
bond market grow from $1.5 billion in 2007 to $389 billion in
2018.  The massive expansion in the market for green bonds,
[4]

a cause for optimism, demonstrates investor desire to stall

climate change. Still, some issuers have been exploiting this
relatively new market’s lack of regulation by “greenwashing”
projects to secure more funding.

Defining “Green”
            The problem of greenwashing comes down in the main
to a singular issue: definitions. Words like “green”
and “sustainable” have become a rallying cry for climate
activists. Though such words have gained popularity and
helped raise awareness of climate change, their lack of
specificity may be harming the movement. The general
sentiment of concepts like “green” and “sustainable” places
importance on the environment while still encouraging
development and advocating for equity. Disagreements arise
when examining the tradeoffs of linking environment,
development, and equity. Even the UN definition of
sustainability, “meeting the needs of the present without
compromising the ability of future generations to meet their
own needs,” seems disappointingly vague.  Because of these
[5]

indistinct definitions, different countries have varying criteria

to qualify for “green” labels. Consequently, international
investors have an especially hard time navigating the green
bond market. 

            This lack of clear definitions results in confusion and

errors when it comes to policy. The United Nations
Conference on Environment and Development (UNCED), held
in Rio de Janeiro in 1992, first highlighted the importance of
universal definitions and measurements for easily
interpretable sustainability indices.  Since then, over 500
[6]

sustainability indices have emerged, evaluating countries on

three dimensions: economic, environmental, and social
conditions. In their analysis of 11 well respected indices,
Böhringer and Jochem observe that despite the indices’ best
efforts to be concise and transparent, they fail to meet
fundamental scientific requirements.  Because of the
[7]

ambiguity in definition, measurements across countries are

simply too varied to make any sort of meaningful
comparison. 
            In the same way, some issuers of green bonds take
advantage of the ambiguity of the word “green.” Since there is
no law governing what can be called green, some issuers
exaggerate any possible aspect of a project that could be
interpreted as green. Repsol’s issuance of green bonds is one
notable example of this kind of greenwashing . In 2017 Repsol
issued the first green bond by an oil and gas company,
claiming the funds would help them operate more efficiently,
and thereby help reduce its carbon footprint.  Clearly, funding
[8]

an oil company is not what most investors have in mind when

purchasing a green bond. Yet, Repsol was able to use the lack
of definition and regulation on what constitutes “green” to its
advantage. 

Issuers of Green Bonds

            According to an Institute for Climate Economics 2016
report, there are seven types of green bonds: 1) Corporate
bonds backed by a corporation’s balance sheet, 2) Project
bonds backed by a single or multiple projects, 3) Asset-backed
securities (ABS) or bonds collateralized by a group of projects,
4) Covered bonds with a recourse to both the issuer

and a pool of underlying assets, 5) Supranational, sub-

sovereign and agency (SSA) bonds issued by IFIs and various
development agencies, 6) Municipal bonds issued by
municipal governments, regions, or cities, and 7) Financial
sector bonds issued by an institution to finance on-balance
sheet lending.  In this section, we will examine differences in
[9]

green label standards for bonds issued by the World Bank, in

the EU, and in China. The World Bank issues SSA bonds and
follows voluntary guidelines to please investors. Within the EU
each country has its own regulations for the various types of
bonds, though investors have incentivized issuers to be
especially transparent regardless of regulations. China has
four different bodies each responsible for regulating different
types of bonds, allowing for more cases of greenwashing than
within the EU. 

Green Bonds Issued by the World Bank

            SSA bonds are worth talking about for two reasons.
Firstly, as mentioned earlier, IFIs and MDBs were the first
institutions to issue green bonds, thus spurring this now
massive market. Secondly, as such institutions do not pursue
the goal of profit maximization, more emphasis is placed on a
project’s environmental effects. For example, the World Bank’s
criteria for project selection was praised in an independent
review by the Center for International Climate and
Environmental Research at the University of Oslo (CICERO) as
being a sound basis for selecting climate-friendly projects.
 CICERO describes the World Bank’s project selection process
[10]

in the following way. Eligible projects include those that

mitigate effects of climate change, such as investments in low-
carbon and renewable energy. Secondly, eligible projects
include those that target the adaptation to climate change,
often infrastructure, or climate-resilient growth projects.
Importantly, no fossil fuel power generating projects are
eligible for funding from World Bank issued green bonds.
Experts in fields such as energy, climate change, transport and
environment are responsible for selecting eligible projects.
Finally, once a project has been approved, there are robust
systems in place to monitor and report on the progress of the
project.  For example, impact reporting is in effect an investor
[11]

newsletter listing relevant statistics and results so details of

the project’s environmental impact are more readily available
to the investor. 

            Impact reporting in particular, while incurring an extra

cost on the issuer of the bond, provides investors with an
extra incentive to invest as they can read about the positive
effects of their investments. Recognizing the importance of
impact reporting, the World Bank (along with several other IFIs
and MDBs) has collaborated with the International Capital
Markets Association (ICMA) in an effort to create a
harmonized framework for impact reporting.  ICMA published
[12]

up to date guidelines
(https://www.icmagroup.org/assets/documents/Sustainable-
finance/2021-updates/Green-Bond-Principles-June-2021-
140621.pdf) in June 2021 (dubbed the Green Bond Principles
or GBP), placing an important role on transparency and
disclosure in an effort to increase the perceived integrity of
the green bond market. [13]

            ICMA’s GBP are made up of four core components

along with two key recommendations for heightened
transparency. The four core components are: 1) Use of
proceeds, 2) Process for evaluation and selection, 3)
Management of proceeds, and 4) Reporting. The two key
recommendations are: 1) Green bonds frameworks, and 2)
External reviews. Within the use of proceeds documentation
an issuer must describe both what eligible green projects will
be funded, and how such projects will be funded through the
proceeds of their green bond. ICMA lists ten categories of
eligible projects, ranging from renewable energy to clean
transportation. Next, the issuer must provide a document
explaining the environmental sustainability objectives of the
eligible green project(s) and how they align with their
respective eligible project category. Under the management of
proceeds requirement, the issuer is encouraged to provide
investors with regular updates about the whereabouts of the
net proceeds raised by the bond throughout the duration of
the project. Finally, the issuer should make annual reports
regarding the use of proceeds to keep investors informed. [14]

            If issuers would like to demonstrate to their investors a

heightened commitment to transparency, they can follow the
key recommendations as well. Firstly, by publishing a green
bond framework the issuer can summarize how its green
bond aligns with the five high level environmental objectives
of the GBP (climate change mitigation, climate change
adaptation, natural resource conservation, biodiversity
conservation, and pollution prevention and control). Lastly,
issuers are encouraged to appoint an independent external
review provider to provide investors with an unbiased
assessment of the integrity of their green bond.  ICMA’s work
[15]

on GBP is a good first step towards ensuring trust in green

bonds, although the guidelines are completely voluntary and
unenforceable. The voluntary nature of such guidelines allows
greenwashers to be intentionally vague or misleading.

EU Standards and Norms

            Currently, there is no legally binding European
consensus on green label standards, rather each country is
responsible for setting national regulations. While the EU
Green Bond Standard (EU GBS) has yet to be adopted into law,
European investors have demonstrated their collective power
in minimizing greenwashing within the EU by incentivizing
issuers to value transparency and disclosure. Furthermore,
their collective action has indirectly prompted the European
Commission to pursue legislation adopting an EU GBS.

            After Repsol issued its green bond in 2017, the

controversy quickly turned to outrage amongst investors. As
European investors made their dissatisfaction heard, a
dialogue between issuers and investors sparked a change in
mindset. It became clear to European issuers that if their
green bonds were to be successful within the EU, they would
have to publicly signal their plans to initiate and accelerate
sustainable business models. According to a special feature in
a Bank for International Settlements (BIS) quarterly review, for
some corporate issuers this new approach has even resulted
in better pricing and lower market execution risk compared to
traditional bonds. [16]

            Upon realizing the benefits of such transparency and

disclosure for both investors and issuers, the Commission’s
High-Level Expert Group on sustainable finance
recommended establishing an EU GBS in a report released in
January 2018.  “Creating an EU Green Bond Standard and
[17]

labels for green financial products” was then included as an

action in the 2018 Commission action plan on financing
sustainable growth.  On June 18th, 2019, the Commission’s
[18]

Technical Expert Group on Sustainable Finance (TEG)

published its assessment of an EU GBS. The report proposed
that the Commission creates a voluntary EU GBS to
strengthen effectiveness, transparency, comparability, and
credibility of the green bond market.  The TEG’s final report
[19]

built on its interim report (published March 6th, 2019) after

receiving feedback from more than 100 organizations.
 Recognizing the importance of such standards, a large
[20]

majority of participating stakeholders supported the creation

of a voluntary EU GBS. This prompted the TEG to give usability
guidance and an updated proposal for an EU GBS in its March
2020 report. The report acts as a guide to issuers for the
proposed EU GBS and the set-up of a market based
registration scheme for external verifiers. It also contains
some updates on the proposed standards. [21]

            The actual document contains 51 pages of

explanations, definitions, regulations, and implementation
guidance influenced by ICMA’s GBP. The TEG’s proposed
model is made up of four core components: 1) The alignment
of the use-of-proceeds with the EU Taxonomy; 2) The content
of a green bond framework to be produced by the issuer; 3)
The required allocation and impact reporting; and 4) The
requirements for external verification by an approved verifier.
Thus, for an issuer to receive a green label the issuer must
firstly publish a green bond framework at or before the time
of issuance. The framework must clearly describe (i) the
issuer’s green bond strategy and alignment with the EU
taxonomy; (ii) the types of green project categories to be
financed; and (iii) the methodology and process regarding
allocation and impact reporting. Secondly, the issuer must
produce annual allocation reports and at least one impact
report throughout the allocation of funds. The annual
allocation reports must include (i) a confirmation of alignment
with EU GBS; (ii) a breakdown of allocated amounts per
project or portfolio; and (iii) a geographical distribution of
projects. Finally, an external verifier (as defined by the TEG)
must approve the green bond framework, the final allocation
report, and the impact report published by the issuer. If all
steps are followed successfully, the issuer—whether located
inside or outside the EU—will receive a green label for their
bond.[22]
            In response to the TEG’s work, the Commission
launched two parallel consultations exploring the possibility of
a legislative initiative for an EU GBS. Firstly, the public
consultation on the renewed sustainable finance strategy
(running from 6 April 2020 – 15 July 2020) aimed to collect the
views and opinions of interested parties as to inform the
Commission’s renewed strategy on sustainable finance.
 More importantly, the targeted consultation on the EU GBS
[23]

(running from 12 June 2020 – 2 October 2020) aimed to

determine the nature of the EU GBS’s legal form.  As a result
[24]

of these consultations, President von der Leyen announced

the establishment of an EU GBS as a key new initiative for
2021 in her State of the Union 2020 speech. In the same
speech she announced that the Commission will set a target
for 30% of the Next Generation EU fund’s 750 billion euros to
be raised through green bonds.  Just over a month later, the
[25]

Commission published the Commission Work Programme

2021, scheduling the legislative proposal for an EU GBS to be
delivered in the second quarter of 2021. [26]

            Since the Repsol scandal in 2017 there have been few

cases of greenwashing as controversial within the EU.
Investors’ close monitoring of the market in Europe has
caused issuers to voluntarily emphasize transparency and
disclosure. In fact, a Climate Bond Initiative (CBI) report on the
green bond market in Europe in 2018 asserts that over 98% of
green bonds issuance in Europe receives at least one review
from independent institutions such as Vigeo Eiris or CICERO.
 Despite this oversight, there are still the occasional cries
[27]

from investors alleging greenwashing within the EU. For

example, in 2019 a representative of Nuveen, an American
asset manager, accused Italian electricity giant Enel of
greenwashing their green bonds. The allegation claimed Enel’s
green bond was linked to a commitment to increase the
coupon by 25 basis points if the company failed to meet its
renewables capacity development targets by the end of 2021.
 Enel has publicly provided green bond reports for 2017,
[28]

2018, and 2019, while also providing several investor

presentations.  Upon independently reviewing Enel’s green
[29]

bonds in October 2020, Vigeo Eiris asserts that Enel’s green

bonds are in line with ICMA’s Green Bond Principles detailed
in June 2020.  The issue comes down to definitions. What
[30]

Nuveen considers greenwashing is viewed as acceptable by

Vigeo Eiris and ICMA, once again highlighting the need for
effective legislative standardization.

The Problem with China’s Green Bond

Standards 
            Greenwashing in China is of greater concern. While
China has the world’s second largest and fastest growing
green bond market, it is also particularly infamous for
greenwashing. The People’s Bank of China, the China
Securities Regulatory Commission, the National Development
and Reform Commission, and the Ministry of Finance each
have their own eligibility criteria for green bonds, and are in
charge of regulating a separate portion of the market.  Figure
[31]

1 illustrates China’s method of regulation concerning green

bonds.  These separate taxonomies establishing eligibility
[32]

criteria for green bonds in China have done little more than
cause confusion, especially for foreign investors. 

            Chinese regulations could be more effective at

preventing greenwashing. Where the EU advocates climate
change mitigation and adaptation, a 2019 Climate Bond
Initiative (CBI) report states that Chinese standards generally
highlight the importance of pollution reduction, greenhouse
gas reduction, resource conservation and ecological
protection.  At first glance these seem like a fine set of
[33]

criteria, but there are loopholes that allow for greenwashing.

The criterion for pollution reduction is especially harmful, as it
technically qualifies projects increasing the efficiency of coal
or fossil fuel plants as “green.”  Furthermore, S&P Global
[34]

Ratings analysts Yamaguchi and Ahmad, point out that

Chinese rules allow for up to 50% of green bond proceeds to
pay back bank loans or fund general working capital instead of
funding a specific project (the CBI standard is 5%).  Another
[35]

cause for concern is the Shanghai Stock Exchange (SSE).

According to a 2019 CBI report, the SSE allows corporations to
issue green bonds on the SSE’s platform without even having
to specify the project so long as over 50% of a corporation’s
operating revenue is generated in a defined “green” sector
and at least 70% of the raised funds are used in green sectors.
 While these regulations certainly seem alarming, the same
[36]

CBI report says these regulations may not be always so bad.

            According to the report, China issued $55.8bn in green

bonds on both the domestic and overseas markets in 2019. Of
that $55.8bn, CBI determined $24.5bn (or 43.9% of bonds
issued in 2019) in some way violated their criteria for being
given a “green” label and were thus excluded from CBI’s
internationally aligned green bond database. Upon a more
detailed investigation CBI found at least $12.4bn of the
$24.5bn were actually allocated to green projects that aligned
with CBI’s values. An example of green bonds that had to be
excluded for technical reasons are two bonds issued by
Beijing Enterprises Clean Energy Group Limited (BECEGL), a
company that gets 99% of its revenue from solar and wind
energy.  Because two of its labeled greenhouse bonds use
[37]
27% and 30% of proceeds respectively for general corporate
purpose (larger than CBI’s allowance of 5%) the bonds could
not be included in CBI’s internationally aligned green bond
database.  As a renewable energy company, BECEGL is the
[38]

sort of company an environmentally conscious investor would

want to support. Yet because of its own criteria, CBI cannot
grant BECEGL bonds a green label. When you adjust for cases
like these, a more accurate estimate of newly-issued
greenwashed green bonds in China in 2019 is $12.1bn (or
21.7%). This number is still relatively high, but the drop from
43.9% shows that China’s greenwashing problem might be
exaggerated by confusing regulations and poor
transparency.  Relaxed standards combined with a lack of
voluntary transparency risk alienating foreign investors from
green bonds issued in China.
Source: Climate Policy Initiative

Green Bond Investors

            Adam Smith, often dubbed the father of economics and
capitalism, argues that individuals should act in their own
rational self-interest. This mindset has become engrained in
our financial system. We often see profit maximization
prioritized over other important objectives, such as
sustainable development. To be useful in the fight against
climate change, this mindset of the financial sector will have to
change. Individual investors should consider the
environmental impacts of their investments. This is not a
political issue, but rather an ethical one.

            From a utilitarian perspective, investors have an ethical

responsibility to invest in an environmentally conscious way.
When faced with an investment choice, an investor should
choose the option that will produce the greatest good for the
greatest number of people. Thus, when deciding whether to
prioritize profit maximization or environmental benefits,
investors should consider the environmental externalities
their investment decisions will impose on future generations.
Different ideologies ranging along the spectrum from the
economic left to right will disagree to what extent utilitarian
principles should influence investors’ decisions. Still, most
would agree that if an investor has the financial means to
invest in an environmentally conscious way without any major
sacrifice on returns, then they should do so from an ethical
standpoint. The idea behind the green bond is to provide
investors with a relatively simple means to do so. 

            The two main disincentives to purchasing green bonds

are greenwashing and currency exchange rate volatility. Some
argue the returns on green bonds should be lower than for
traditional bonds due to the increased cost to the issuer of a
green bond brought on by impact reports as well as a
willingness of investors to trade off at least some returns for
the “feel-good” premium of environmental benefits. In
practice, returns on green bonds do not seem to differ
significantly from their traditional counterparts.
[39]

            Greenwashing provides the biggest disincentive to

investors considering green bonds. Some investors simply do
not have time to do the necessary due diligence when figuring
out what sort of project they would like to help fund. The idea
they may be funding a coal plant could be enough to dissuade
an investor from buying any green bond. 

            Exchange rate volatility—particularly in emerging

economies—can influence an investor’s decision to purchase
green bonds. By the time the investor receives returns the
exchange rate between the investor’s domestic currency and
the foreign currency used to pay for the bond might have
depreciated to a level where the investor makes no real gain
(or even incurs a loss) after exchanging back to the domestic
currency.

            Despite these hurdles there is cause for optimism as

investors seem eager to buy green bonds. In fact, a CBI report
covering 46 EUR and USD green bonds during the first two
quarters of 2020 notes the average oversubscription for green
bonds was 2.6x compared to 2.3x for a selection of traditional
bonds.  While EUR and USD green bonds are less likely to be
[40]

greenwashed, this report demonstrates the demand for green

bonds is already high and seems to be growing. 

Policy Implications and Challenges

            Solving the problem of greenwashing will require a
coordinated effort from all actors involved in the green bond
market, including issuers, investors, independent rating
agencies, and governments. 
            Because of the distrust in the green bond market
brought on by greenwashing, issuers of green bonds have
a duty to distinguish themselves from potential greenwashers
by means of transparency and disclosure. Impact reporting
seems to be an effective way of communicating
environmental impacts of projects to investors. Perhaps the
reason some companies are not as transparent as others is
that impact reporting incurs an additional cost on the issuer.
To alleviate this burden, issuers should advocate for
preferential treatment from governments in the form of tax
cuts or subsidies as an incentive to provide quality impact
reports.

            Next, investors, like everyone else, have a responsibility

to fight climate change. There is a good case to be made that
investors have the ethical responsibility to invest green,
thereby doing something good for the vast number of people
who will have to live with the effects of climate change.
Implicitly, this means investors also have the responsibility to
educate themselves to avoid the purchase of greenwashed
bonds. Otherwise, there is little that investors can do on an
individual level. Collectively, on the other hand, investors can
continue applying pressure on other actors in the market to
do everything they can to ensure confidence in the market. 

            Independent institutions such as CBI or CICERO have

important roles to play in the fight against greenwashing.
Providing guidelines to issuers as to how to qualify for a green
label is only one step. Independent rating agencies should
work together to form a universal set of rules. More easily said
than done, collaboration on an international scale would be a
good first step towards this goal. Any guidelines should be
wary of being too limiting as to avoid excluding reasonable
green bonds from attaining a green label (as we observed with
BECEGL in China). Instead, there should be a greater emphasis
on transparency and disclosure. Ideally, judgements could be
made on an individual basis, with a published report detailing
why a bond did or did not qualify for a green label. In practice,
however, this process requires a lot of resources. Finally,
independent rating agencies are useful to investors, but do
not carry any legal power. Thus, such agencies should
continue to advocate for an international organization to
regulate the green bond market. 

            Governments have two main responsibilities in

eliminating greenwashing. Firstly, governments will have to
collaborate to establish an international body to regulate the
market for green bonds. A single universal standard of a green
bond label should reduce investor confusion and mistrust.
Governments could consult with independent rating agencies
when developing those standards. Secondly, governments
should work to incentivize both issuing and buying green
bonds. Whether through tax cuts or subsidies, governments
should explore a variety of incentives.  

            If all actors involved do their part, integrity can be

restored to the green bond market, allowing the market to
continue expanding and for society to reap more of the
benefits of green bonds.

Societal Benefits from Green Bonds

            Green bonds are already benefitting people around the
world on local and global scales. If greenwashing is reduced
they have the potential to be an even more valuable weapon
in the fight against climate change. Green bonds issued by
development banks and IFI’s are particularly important for
developing countries as poorer people will be
disproportionally affected by climate change. Such bonds will
mostly help to fund local scale projects helping people adapt
to harsher conditions. On a more global scale, green bonds
issued by governments and corporations will help to increase
investments into green technologies. With such increases in
investments we can hope to see innovation in renewable
energy, energy efficiency, pollution prevention, and other
exciting areas. With the necessary global cooperation, green
bonds will be a vital component in the fight against climate
change.

            In recent years the gravity of the threats posed by

climate change have become more obvious than ever before.
Likewise, it has become glaringly obvious that everyone has a
part to play in the fight against climate change. This includes
the financial sector. CliFin will become increasingly important
in shifting incentives to drive sustainable development. The
green bond is a relatively recent development within the
financial sector and is already causing optimism and
enthusiasm amongst investors. Still, greenwashing prevents
green bonds from reaching their full potential in the fight
against climate change as the phenomena reduces confidence
in the market for green bonds. The key to eliminating
greenwashing is to create a global consensus on criteria for a
green label. Such criteria should be weary of being too
restrictive or discriminatory, and should instead promote
values such as transparency and disclosure amongst issuers
to ease the minds of investors. Until such criteria are
established, all actors in the green bond market have a
valuable role to play in optimizing the market’s efficiency. 

Works Cited
“10 Years of Green Bonds: Creating the Blueprint for
Sustainability Across Capital Markets.” World Bank,
www.worldbank.org/en/news/immersive-story/2019/03/18/10
-years-of-green-bonds-creating-the-blueprint-for-
sustainability-across-capital-markets.

Ahmad, Rehan, and Yuzo Yamaguchi. “Investors Applaud

China’s Plan to Ban Clean Coal from Green Bond
Financing.” Spglobal.com, S&P Global, 9 Sept. 2020,
www.spglobal.com/marketintelligence/en/news-insights/latest
-news-headlines/investors-applaud-china-s-plan-to-ban-clean-
coal-from-green-bond-financing-60257794.

“Bonds and Climate Change: The State of the Market

2018.” Climate Bonds Initiative, 29 Jan. 2019,
www.climatebonds.net/resources/reports/bonds-and-climate-
change-state-market-2018.

Brown, Phil. Green Bond Comment, June – Of Repsol and

Reputation. Environmental Finance, 7 June 2017,
www.environmental-finance.com/content/analysis/green-
bond-comment-june-of-repsol-and-reputation.html.

Böhringer, Christoph. “Measuring the Immeasurable: A Survey

of Sustainability Indices.” SSRN Electronic Journal, 2006,
doi:10.2139/ssrn.944415. 

“CHINA GREEN BOND MARKET 2019 RESEARCH

REPORT.” Climatebonds.net, Climate Bonds Initiative, 2019,
www.climatebonds.net/files/reports/2019_cbi_china_report_e
n.pdf.

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Endnotes
 https://www.worldbank.org/en/news/immersive-story/
[1]

2019/03/18/10-years-of-green-bonds-creating-the-blueprint-
for-sustainability-across-capital-markets

 https://www.eib.org/en/investor_relations/cab/index.htm
[2]

 www.climatebonds.net/resources/reports/bonds-and-
[3]

climate-change-state-market-2018

 https://jcsr.springeropen.com/articles/10.1186/s40991-020-
[4]

00056-0

 https://www.un.org/en/academic-impact/sustainability
[5]

 https://sustainabledevelopment.un.org/content/
[6]

documents/Agenda21.pdf

 https://reader.elsevier.com/reader/sd/pii/
[7]

S0921800907002029?
token=4505C4EA0FBD8AB1E6D580E0786C65F71A3DB993AB8
5C5BAD0260F882861D97875F4394FA5D1AA4C8E9E9020D4D
D1483&originRegion=eu-west-
1&originCreation=20210622165310

 https://www.environmental-finance.com/content/analysis/
[8]

green-bond-comment-june-of-repsol-and-reputation.html

 https://www.cbd.int/financial/greenbonds/i4ce-
[9]

greenbond2016.pdf

 https://treasury.worldbank.org/en/about/unit/treasury/
[10]

ibrd/ibrd-green-bonds#2
  https://thedocs.worldbank.org/en/doc/
[11]

917431525116682107-0340022018/original/
CICEROsecondopinion.pdf

 https://thedocs.worldbank.org/en/doc/
[12]

47d9c186d2240c33c80132aca47b5737-0340022021/original/
Handbook-Harmonized-Framework-for-Impact-Reporting-
December-2020-151220.pdf

 https://www.icmagroup.org/assets/documents/Sustainable-
[13]

finance/2021-updates/Green-Bond-Principles-June-2021-
140621.pdf

 Ibid.
[14]

 Ibid.
[15]

 T. Ehlers and F. Packer ‘Green Bond Finance and

[16]

Certification’, Bank for International Settlements, 2017.

 https://ec.europa.eu/info/sites/default/files/180131-
[17]

sustainable-finance-final-report_en.pdf

 https://ec.europa.eu/info/publications/sustainable-finance-
[18]

renewed-strategy_en

 https://ec.europa.eu/info/sites/default/files/
[19]

business_economy_euro/banking_and_finance/documents/
190618-sustainable-finance-teg-report-green-bond-
standard_en.pdf

 https://ec.europa.eu/info/business-economy-euro/banking-
[20]

and-finance/sustainable-finance/eu-green-bond-standard_en

 https://ec.europa.eu/info/sites/default/files/
[21]

business_economy_euro/banking_and_finance/documents/
200309-sustainable-finance-teg-green-bond-standard-
usability-guide_en.pdf

 Ibid.
[22]

 https://ec.europa.eu/info/consultations/finance-2020-
[23]

sustainable-finance-strategy_en

 https://ec.europa.eu/info/business-economy-euro/banking-
[24]

and-finance/sustainable-finance/eu-green-bond-standard_en

 https://ec.europa.eu/info/sites/default/files/
[25]

state_of_the_union_2020_letter_of_intent_en.pdf

 https://eur-lex.europa.eu/resource.html?uri=cellar:91ce5c0f-
[26]

12b6-11eb-9a54-01aa75ed71a1.0001.02/DOC_2&format=PDF

 https://www.climatebonds.net/files/reports/
[27]

the_green_bond_market_in_europe.pdf

 https://www.environmental-finance.com/content/analysis/
[28]

in-response-to-accusations-that-enels-sdg-bond-was-
greenwashing.html

 https://www.enel.com/investors/investing/sustainable-
[29]

finance/green-bonds

 https://vigeo-eiris.com/vigeo-eiris-provides-second-party-
[30]

opinion-for-enels-innovative-sustainability-linked-bond/

 https://www.wri.org/insights/will-china-finally-block-clean-
[31]

coal-green-bonds-market

 https://www.climatepolicyinitiative.org/wp-content/
[32]

uploads/2020/06/
The_State_and_Effectinevess_of_the_Green_Bond_Market_in_C
hina.pdf
  https://www.climatebonds.net/files/reports/
[33]

2019_cbi_china_report_en.pdf

https://www.climatebonds.net/files/reports/
[34]

comparing_chinas_green_definitions_with_the_eu_sustainable
_finance_taxonomy_part_1_en_final.pdf

 https://www.spglobal.com/marketintelligence/en/news-
[35]

insights/latest-news-headlines/investors-applaud-china-s-
plan-to-ban-clean-coal-from-green-bond-financing-60257794

 https://www.climatebonds.net/files/reports/
[36]

2019_cbi_china_report_en.pdf

 Ibid.
[37]

 Ibid.
[38]

 https://www.bloomberg.com/news/articles/2020-10-30/why-
[39]

bonds-good-for-the-earth-now-carry-a-greenium-quicktake

 https://www.climatebonds.net/files/reports/cbi-pricing-h1-
[40]

2020-21092020.pdf