Consolidated E&S Methodology - New - 25th Oct

Document type
Ratings
Methodology
December 2021
Month Year
RATINGS METHODOLOGY | Month Year
Contents
Data Collection Scope 4
Disclosures/Reports to be Used 9
Key Issues 10
Access to Communication 10
Access to Finance 18
Access to Healthcare 30
Biodiversity & Land Use 47
Chemical Safety 75
Climate Change Vulnerability 92
Common LM/HCD 100
Community Relations - Corruption & Instability 130
Community Relations - Biodiversity 139
Consumer Financial Protection 152
Controversial Sourcing 175
Corporate Behavior 184
Corruption & Instability 201
Electronic Waste 207
Financing Environmental Impact 214
Health & Safety 253
Human Capital Development 286
Insuring Health Demographic Risk 310
Labor Management 316
Opportunities in Clean Tech 330
Opportunities in Green Building 380
© 2021 MSCI Inc. All rights reserved. Please refer to the disclaimer at the end of this document. MSCI.COM | Page 2 of 696
Opportunities in Nutrition Health 403

Opportunities in Renewable Energy 419
Packaging Material & Waste 429
Privacy & Data Security 446
Product Carbon Footprint 474
Product Safety & Quality 494
Raw Material Sourcing 560
Responsible Investment 577
Supply Chain Labor Standards 592
Toxic Emissions & Waste 606
Water Stress 641
Appendix I | QC Process 688
Appendix II | Japan and China Default Scoring 690
Appendix III | Sources 691
Appendix IV | Track Changes 692
Data Collection Scope

Company Filings
In the Company Filing section, provide the following information of the disclosure:
• Filing Type (i.e., AR Filing, CSR Filing, and Integrated Filing)
• Filing Sub-Type (i.e., Annual Report, 10-K*, 20-F, 40-F, Annual Information Form,
Financial Statement, Corporate Sustainability Report (CSR), Sustainability
Report, ESG Report, Integrated Report, Annual and Sustainability Report, and
GRI Report)
• Filing Used Date
• Filing Release Date
• Comment
• Fiscal Year End
• Disclosure Language (e.g., English, Arabic, Bahasa Indonesian, Danish, Finnish,
etc.)
The below steps should be followed while checking the filings used:
• Check the filing used in Company Filings section under ‘Company’ tab.
• If latest AR/CSR is not yet profiled, please check company website/document
repository for any new documents.
• If there is a new document (i.e., AR/CSR), please revert the task to the vendor
via Ad hoc SharePoint page. If there are no new disclosures, please continue
the review.
• Note that when raising on SharePoint page, please enter ‘Data Ops Team’ in
‘Requested By (Team)’ field.
Year End
Follow the below procedure when creating rows for series data points.
Fiscal Year End Row to be Created Example
FYE: 01/30/2020
01/30 – 05/30 YE - 1
Row: 2019
FYE: 06/30/2020
06/01 – 12/30 YE
Row: 2020
Dual Listed Entities

Dual listed entities should have the same scoring. Scores of the main entity should
be checked and reflected on its child entity.
Main IID (From) Main Entity Child IID (Target) Child Entity
IID000000002132259 BHP Group PLC IID000000002158721 BHP Group Limited
IID000000002181514 Rio Tinto PLC IID000000002141742 Rio Tinto Limited
IID000000002140917 Carnival Corporation IID000000002161115 Carnival Plc
IID000000002171363 INVESTEC PLC IID000000002135195 INVESTEC LIMITED
IID000000005014709 Ninety-One PLC IID000000005014714 Ninety-One Ltd
Scoring Data Points

Stale Data
• Data is considered as ‘stale’ if the evidence found is ≥ 3 years. In that case, the
scoring should be downgraded to ‘No evidence’ or ‘No’ if after 3 years there is
still no evidence found.
• Example: Employee engagement survey results
Report Evidence Score
Company discloses engagement
2019 YE Evidence found from 2019 report
results
No evidence found from 2020 –
2021 YE No evidence
2021 disclosures
Below are the general procedures on how to update datapoints change by Content
or ICP. If there is a specific procedure on the datapoint, kindly follow it instead of
the general procedure.
Content Analyst Updated the Data Point

• No evidence found – If no evidence found, do not change the score to ‘No’ or
‘No evidence’ unless the data is already considered as ‘stale’ data.
• Higher scoring – if the evidence found will require higher scoring, change the
scoring based on the evidence.
• Lower scoring – if the evidence found will require to downgrade AND data is
not stale, do not downgrade the score.
ICP Updated the Data Point

• Do not make any changes on qualitative data unless
o data is considered as stale
o if the evidence found requires higher scoring
• Update the quantitative data especially if
o data is an outlier or
o there is a huge YoY change
QC Scope for Series Data Points

• The general procedure for series data points is to update the one-year scope
data.
•For issuers that will be profiled for the first time, update the three year-scope
data.
Follow below procedure on updating specific data points.
Key Issue Table Guidance
- Add a row for the latest fiscal year and mark as Scope not
Water Withdrawal
determinable if there are no disclosures yet.
Water Consumption Performance
- If no table is present, add data for latest 3 years.
Water Stress
- Add a row for the latest fiscal year (for Weighted Water Stress)
- If no table is present, add data for latest 3 years.
Water Intensity Reported
- For non-weighted water stress, do not add rows and retain
published rows (if there are any).
- Add a row for the latest fiscal year and mark as No evidence if
Layoffs and M&A Events
there are no disclosures of layoffs or M&As.
- Add a row for the latest fiscal year and mark as No evidence if
Training & Development
there are no disclosures yet.
Employee compensation, stability
Common LM/HCD - Add a row for the latest fiscal year even with no disclosures.
& productivity metrics
Strikes, work stoppages and lock- - Only add new rows for fiscal years with evidence of strikes.
outs Delete published rows if there is no evidence.
- Dependent on exposure update (update the row/s available)
Total workforce composition - If data is provided in company reports but there is no new row
added yet, place data in the Internal Notes.
Government Ownership and - Add a row for the latest fiscal year and mark as No evidence if
Corporate Behavior
Involvement there are no disclosures yet.
- Add a row for the latest fiscal year if there is total workforce data
from Total Workforce Composition table in Common LM/HCD. Do
not add rows in HCD if the total workforce is not yet updated by
Exposure Team.
Human Capital
Workforce Diversity - For published rows with no equivalent row in Total Workforce
Development
Composition in Common LM/HCD, do not delete row/s. Retain the
published data.
- Do not add rows for index adds that have no Total workforce
composition data.
- Add a row for the latest fiscal year, if toxics data (following
Performance Tables for NOX,
Toxic Emissions and industry-specific guidance) is available and has been available for
SOX, VOC, PM, Haz, Non-Haxz
Waste* (for industries previous years. Do not add rows if data has not been historically
etc.*
with TEW as default available. Delete published rows if there is no evidence.
KI) - Only add new rows for fiscal years with evidence of new
Certifications
certifications. Delete published rows if there is no evidence.
- Add a row for the latest fiscal year if H&S data (following
industry-specific guidance) is available and has been available for
Certifications
previous years. Do not add rows if data has not been historically
available. Delete published rows if there is no evidence.
Health & Safety
Performance Tables for Lost - Add a row for the latest fiscal year if H&S data (following
Time Incident Rate, Total industry-specific guidance) is available. Do not add rows if there is
Recordable Injury Rate, Fatalities, no evidence found. Do not add rows if data has not been
and Other H&S Metrics historically available. Delete published rows if there is no evidence.
Biodiversity and Land Only add row if there is evidence. Delete blank published rows if
Fresh Water Used
Use ensured that there is no evidence.
Always indicate in the Internal Notes the presence (data, notes, calculations, etc.) or
absence of data.
Non-Metric Data points under Non-Weighted Key Issue

• If the Key Issue is non-weighted, only metrics data points should be scored.
• If the Key Issue is non-weighted but a non-metrics data point was previously
scored, the scoring will not be updated or changed to no value; previous scores
will be retained.
Source Field
1. Do not delete any published sources unless it is incorrect.
2. Only put sources in these fields. Do not put notes or other information.
3. Format:
Source Format Example
Access
mm/dd/yyyy
Date Access Date 01/01/2022
Document
Document Page Number (if applicable) * AR 2020 page 45/250
Fiscal Year (if applicable)
Name *PDF document page number
Access
mm/dd/yyyy Access Date 01/01/2022
Date
Website Company Website:
Company
Website link https://www.bxp.com/privacy-policy
Website
4. AVOID doing the following:

a. Delete previous sources.
b. Including name of the vendor firm (SGA) or name/initials of analysts.
c. Avoid quotation marks since they cause error in data feed. If analyst
still want to use it, then following are examples of what is acceptable
and not acceptable.
▪ ‘MSCI” – not acceptable, “MSCI – not acceptable, ‘’MSCI – not
acceptable, “MSCI” – acceptable
d. Avoid any types of lines. e.g., ……. Or ======= OR -----------
Details Field
1. Only put additional information about the data point/s.
2. Example:
Data Point Details
Salary per Employee Salary Expense: xx,xxx EUR ~ xx,xxx USD
(in USD) Total Workforce: xxx employees
Profit per employee
Net Income: xx,xxx GBP ~ xx,xxx USD
(USD ‘000)
Total Workforce: xxx employees
3. AVOID doing the following:

a. Putting internal notes.
b. Including name of the vendor firm (SGA) or name/initials of analysts.
c. Avoid quotation marks since they cause error in data feed. If analyst
still want to use it, then following are examples of what is acceptable
and not acceptable.
▪ ‘MSCI” – not acceptable, “MSCI – not acceptable, ‘’MSCI – not
acceptable, “MSCI” – acceptable
d. Avoid any types of lines. e.g., ……. Or ======= OR -----------
Disclosures/Reports to be Used
Related Entities
While profiling related entities, please follow below guidelines:
• Parent’s Report - Use parent data when the company does not provide any
disclosures. In case there is a certain group-wide policy (as stated by the
parent) for which the subsidiary does not provide any disclosures, you can use
the parent-level input.
• Quantitative Data - Never use any quantitative data of a parent for its
subsidiary. The scope of programs and targets of parent’s disclosure should
be checked for applicability.
Mortgage REITS
Internally vs. externally managed mREITs
• Because REIT is a specific legal structure, some have no or very few
employees and are managed by a third-party which created the REIT and
retains control over its operations. In such cases, the relevant information (e.g.
policies and practices involving people) is at the external manager’s level, not
the scored REIT’s level.
Internally managed mREITs
• We score Key Issues for internally managed mREITs by looking at their
own disclosures.
Externally managed mREITs

• We apply look-through approach and score Key Issues for externally
managed mREITs by looking at disclosures in the following order:
1. The external manager’s disclosures
2. The externally managed company’s (mREIT’s) disclosure.
3. If neither provides disclosure, apply highest deduction/no
evidence to the relevant indicators.
Key Issues
Access to Communication
This issue evaluates the extent to which companies take advantage of opportunities
for growth in developing countries and underserved markets (e.g., rural, elderly).
Scores are based on exposure to underserved regions; current initiatives and
philanthropic efforts; and targets to expand to underserved segments.
*Note: This key issue is mostly focused on emerging / developing market activities
related to ATC that aim to diminish the digital divide and promote digital inclusion.
An exposure to underserved communities based on the extent to which companies
have operations in emerging / developing countries.
Practices
Support for services such as mobile banking, healthcare, agriculture or
other
• Definition: This data point refers to the support for services such as mobile
banking, healthcare, agriculture or other
• Dropdown choices:
(a) Substantial involvement (eg. partnership with governments, NGOs,
companies to deliver services, widespread usage of platforms)
(b) Limited involvement (eg. mobile app platforms, partnership with Govt,
NGOs to transmit information about essential services)
(c) General statement to support essential services in developing markets
(d) No evidence
• Keyword(s):
mobile banking, healthcare, agriculture, services, government, NGO,
Partnership
• General Procedure:
- This can be also found on CSR activities in Company website
- Scoring:
o Substantial involvement (eg. partnership with governments,
NGOs, companies to deliver services, widespread usage of
platforms) – if the company disclose a service that supports on
mobile banking, healthcare, agriculture or having a big
partnership with government or any local government that are
already embedded on their business operations.
o Limited involvement (eg. mobile app platforms, partnership
with Govt, NGOs to transmit information about essential
services) – if the company only disclose a service or involve on
one certain service.
o General statements to support essential services in

developing markets - if the company only disclose a certain
support on digitalization in community without stating a
programs or certain events in emerging / developing market.
o No evidence - No disclosure found.
Current Operations
Type of philanthropic activities that support access to communication in
developing activities
• Definition: Does the company engaged in philanthropic activities that
explicitly support access to communications in developing activities?
(a) Long-term infrastructure or product donation / subsidy programs
(b) Short-term donations programs and/or disaster relief
(c) No philanthropic activities
• Keyword(s):
infrastructure, donation, help victim, programs, relief, disaster,
reenergization, philanthropic
- This is specific to initiative on having philanthropic activities in
emerging / developing countries.
- Scoring:
o Long-term infrastructure or product donation / subsidy
programs – if the company disclose an initiative on any
infrastructure or telecommunication wires / poles/ services
to support access in communication in emerging /
developing markets
o Short-term donations programs and/or disaster relief –
this usually pertains on any disaster relief or reenergization
Groups served including developed markets

Inclusion of elderly people in accessibility programs
explicitly support elderly people?
(a) Yes
(b) No
(c) Not Disclosed
• Keyword(s):
Elderly, seniors
- This interconnects with the Type of Philanthropic data point, whether it
includes an engagement in the philanthropic activities.
- Important Note: if the company does not have a philanthropic activity
but have an initiative on serving accessibility on communication in
emerging / developed markets, this could be scored as Yes. Commented [LRA1]: @Atilano, Cristine Joyce let’s
• Guidelines for Specific Industry / Market discuss this important note.
Specific Guidelines
- For any telecommunications with a business on tower infrastructure,
leasing, or telecom companies in Emerging Market.
o Note: Even if the company has an initiative on serving
accessibility on communication in emerging / developed
markets, follow default scoring.
- Default Scoring: No value
- Exception: Score for this datapoint “Inclusion of remote areas
development in accessibility programs”
- NOTE: Change the score to No value even for the Publish data.
Inclusion of children in accessibility programs

explicitly support children?
(a) Yes
(b) No
(c) Not Disclosed
• Keyword(s):
Children, child, schools
emerging / developed markets, this could be scored as Yes.
• Guidelines for Specific Industry / Market
Industry Guidelines
- Sub-Industry: Integrated Telecommunication Services, Wireless
Telecommunication Services
- Default Scoring: Yes
Specific Guidelines

Inclusion of people with disabilities in accessibility programs

explicitly support people with disabilities?
(a) Yes
(b) No
(c) Not Disclosed
• Keyword(s):
disability, disabilities
Specific Guidelines
Inclusion of low-income households in accessibility programs

explicitly support low-income households?
(a) Yes
(b) No
(c) Not Disclosed
• Keyword(s):
low income, low-income, households, home
Industry Guidelines
- Sub-Industry: Integrated Telecommunication Services, Wireless
Telecommunication Services
Specific Guidelines
Inclusion of remote areas development in accessibility programs

explicitly support in remote areas?
(a) Yes
(b) No
(c) Not Disclosed
• Keyword(s):
remote areas, rural areas, remote communities

Current operations include

Direct ownership or fully owned subsidiaries in emerging market
• Definition: Direct operations or fully owned subsidiaries in emerging
markets?
(a) Yes
(b) No
(c) Not Disclosed
• Keyword(s):
operations, subsidiaries, operate
- The key here if the companies listed on subsidiary list in annual reports
is a good place to start; not the most ideal indicators but supposed to
measure degree of on the ground presence in EMs.
- Important Note: these initiatives are also present in companies with
major operations in developed countries.
- Scoring:
o Yes - if the company domicile falls under emerging market
which have an operation or have a direct ownership or fully
owned subsidiaries
China A
- Sub-Industry: Alternative Carriers; Integrated Telecommunication
Services; Wireless Telecommunication Services
Ownership stakes in regional operators

• Definition: Ownership stakes in regional operators?
(a) Yes
(b) No
(c) Not Disclosed
• Keyword(s):
operations, subsidiaries, operate
- The key here if the companies listed on subsidiary list in annual reports
is a good place to start; not the most ideal indicators but supposed to
measure degree of on the ground presence in EMs.
- Important Note: these initiatives are also present in companies with
major operations in developed countries.
- Scoring:
o Yes - if there is an ownership stakes in regional operators
such as owning a share / joint operation with other
companies within emerging market.
Targets for Expansion

Targets for implementing Access to Communication (ATC) or Digital
Divide
• Definition: Does the company have targets for implementing its Access to
Communication (ATC) or Digital Divide strategy?
(a) Targets to expand in EMs beyond current operations
(b) Targets to improve/expand only in its current markets
(c) General statement on expansion without details on the nature or countries
of the expansion
(d) No expansion plans to EMs detected
• Keyword(s):
expansion, improve, expand, expanding, enhance, grow, digital divide
- Specific strategy in developing / emerging countries on expansion
- Important note: These initiatives are to be implemented within a
specific time frame or usually forward looking. Look for target
disclosures BEYOND current markets and operations.
- Scoring:
o Targets to expand in EMs beyond current operations - if
the company is listed in EMs or has existing operations in
EMs and disclose that they are targeting to expand beyond
current operations.
o Targets to improve/expand only in its current markets – if
the company only target to expand or improve within its
current market
o General statement on expansion without details on the
nature or countries of the expansion - when company
didn’t specifically stated details on expansion.
No expansion plans to EMs detected – No disclosure/ No

o
Targets
China A
- Sub-Industry: Alternative Carriers; Integrated Telecommunication
Services; Wireless Telecommunication Services
- Default Scoring: General statement on expansion without details on the
nature or countries of the expansion
Access to Finance
for growth and strengthening their reputation in developing countries and
underserved markets (e.g., rural, small business). Scores are based on exposure to
underserved regions; initiatives, products, and distribution channels targeting the
underserved; and the level and trend of small-and medium-enterprise (SME)
financing.
Banks:
Most the industry has at least some exposure to underserved markets. Ignoring
underserved markets may be an opportunity lost to competitors. New markets could
offer extraordinary growth opportunities, but also risks.
Consumer Finance:
Most companies in the industry have at least moderate exposure to underserved
markets. New markets could offer a company opportunity to grow its customer base,
provided that credit risk inherent to these segments is well-managed.
Life & Health Insurance:
Life & health insurers have opportunities to serve underinsured populations and take
advantage of opportunities for growth and strengthening of their reputations in
developing countries and underserved markets.
Supranationals & Development Banks (S&DBs):
S&DBs generally operate under the policy mandate of economic and social
development objectives. Social impact missions through financing activities may
provide a long-term license to operate in a society and enhance economic relevance
in the eyes of the member states and the public.
Sources:
• Annual Report/10K • Company website (under SME)
• ESG/Sustainability/CSR report • Call Reports
• Investor Presentation • Pillar 3 Disclosure
Performance
SME business - assessment
• Definition: Compare the difference between companies’ SME % vs
domestic peers’ average SME %
(a) Global leader on SME finance (over 40% of total lending)
(b) Above-average level of SME finance
(c) Average level of SME finance
(d) Below-average level of SME finance

(e) Limited or no evidence of SME finance
• Keyword(s):
‘SME’, ‘MSME’, ‘SMME’, ‘small business’, ‘small and medium enterprise’,
‘microenterprise’
- Use the Social Impact excel file in Document/Extractions.
o Go to Document/Extractions.
o In Documents tab, search Social Impact excel file for latest
year.
o Social Impact Report will give the following information that
can be used in SME business – assessment and SME
lending growth rate (% year-on-year) dps.
• Loans to SMEs%
• Loans to SMEs
o Use Loans to SMEs% to score this datapoint.
- If Social Impact excel file is not available, check company’s
disclosures. This may be disclosed or calculated – if calculated, be
sure to make relative to total loans and not absolute growth.
- To consider in ‘Average level of SME finance’ option, check the
Issuer Country of Domicile in the below list.
- If country of domicile is not included in the list, use the guidelines
under Scoring section.
Developed Market
Country Recent SME ratios of
country average
Japan 51.2%
Germany 44.7%
Israel 25.6%
Denmark 22.9%
Finland 22.9%
Italy 21.4%
Norway 17.5%
Spain 16.3%
Switzerland 16.0%
Belgium 12.9%
United Kingdom 10.3%
Austria 9.6%
United States of America 9.5%
Netherlands 9.1%
Sweden 9.0%
Singapore 8.9%
France 8.6%
Australia 5.6%
Canada 5.1%
Hong Kong 4.8%
Emerging and Frontier Markets

Country
Country Recent
RecentSME
SMEratios
ratiosofof Country
Country Recent
RecentSME
SMEratios
ratiosofof
countries
countriesaverage
average countries
countriesaverage
average
Kenya
Kenya 62.6%
62.6% Slovakia
Slovakia 12.4%
12.4%
South
SouthKorea
Korea 44.5%
44.5% Brazil
Brazil 12.3%
12.3%
Kazakhstan
Kazakhstan 42.9%
42.9% Chile
Chile 11.7%
11.7%
Morocco
Morocco 27.7%
27.7% Hungary
Hungary 10.6%
10.6%
Turkey
Turkey 24.3%
24.3% Poland
Poland 10.2%
10.2%
Taiwan
Taiwan 23.4%
23.4% Qatar
Qatar 9.8%
9.8%
Greece
Greece 22.5%
22.5% Nigeria
Nigeria 9.1%
9.1%
India
India 21.3%
21.3% Luxembourg
Luxembourg 8.1%
8.1%
Thailand
Thailand 21.0%
21.0% Russia
Russia 8.0%
8.0%
Mexico
Mexico 20.7%
20.7% Philippines
Philippines 6.8%
6.8%
China
China 19.8%
19.8% Saudi
SaudiArabia
Arabia 6.6%
6.6%
Indonesia
Indonesia 19.2%
19.2% South
SouthAfrica
Africa 6.5%
6.5%
Malaysia
Malaysia 18.6%
18.6% Colombia
Colombia 6.3%
6.3%
Peru
Peru 17.9%
17.9% Ukraine
Ukraine 5.8%
5.8%
Ireland
Ireland 17.3%
17.3% Czech
CzechRepublic
Republic 3.6%
3.6%
Cyprus
Cyprus 14.6%
14.6% Argentina
Argentina 3.0%
3.0%
Portugal
Portugal 13.5%
13.5% Mauritius
Mauritius 2.1%
2.1%
- Scoring
o Global leader on SME finance (over 40% of total lending) –
o More than 40% of SME financing
o Exceptions for a country having more than 40% of
average SME lending.
▪ 10% threshold is also applicable. For example,
in Japan, 50% is the average ratios of SME
lending, 55% to 65% is the Above, and more than
65% is the Global Leader
o Above-average level of SME finance - More than 5% of a
country’s average ratio (e.g., the average is 8% in the US, more
than 13% is Above-average)
o Average level of SME finance - Between +5% to -5% of a
country’s average ratio
o Below-average level of SME finance - Less than -5% of a
country’s average ratio
o Limited or no evidence of SME finance - No evidence. If a
company only mentions SME lending involvement without the
amount, we score them as No Evidence

Industry Guidelines
- Sub-Industry: Life & Health Insurance, Multi-line Insurance, Property

& Casualty Insurance, and Insurance Brokers
- Default Scoring: leave data point as "No Value” (Not Applicable)
- Sub-Industry: Consumer Finance

- Procedure:
o If this data point is ‘No Value’ AND the change was from
Content Team, please do not update.
o Reason: Some Consumer Finance cater 100%
retail/individual loans (e.g., student loans) hence SME dps
become irrelevant.
SME lending growth rate (% year-on-year)

• Definition: Indicates the SME lending growth rate (% year-on-year)
N/A - Numeric Input Value
• Keyword(s):
- Use the Social Impact excel file in Document/Extractions.
o Go to Document/Extractions.
o In Documents tab, search Social Impact excel file for latest
year.
o Social Impact Report will give the following information that
can be used in SME business – assessment and SME
lending growth rate (% year-on-year) dps.
• Loans to SMEs%
• Loans to SMEs
o Use Loans to SMEs latest value and previous value to
compute for the SME lending growth rate (% year-on-year).
𝐿𝑜𝑎𝑛𝑠 𝑡𝑜 𝑆𝑀𝐸𝑐𝑢𝑟𝑟𝑒𝑛𝑡 − 𝐿𝑜𝑎𝑛𝑠 𝑡𝑜 𝑆𝑀𝐸𝑝𝑟𝑒𝑣𝑖𝑜𝑢𝑠
𝑺𝑴𝑬 𝒍𝒆𝒏𝒅𝒊𝒏𝒈 𝒈𝒓𝒐𝒘𝒕𝒉 𝒓𝒂𝒕𝒆 =
𝐿𝑜𝑎𝑛𝑠 𝑡𝑜 𝑆𝑀𝐸𝑝𝑟𝑒𝑣𝑖𝑜𝑢𝑠
- If Social Impact excel file is not available, check company’s
disclosures. And compute using the formula above.
- Leave blank instead of updating to zero

Industry Guidelines

- Procedure:
become irrelevant.
SME business growth - assessment

• Definition: Indicates SME portfolio lending growth - assessment of the
company relative to regional peers
(a) Sector-leading growth in SME finance relative to previous years
(b) Significant growth in SME finance relative to previous years
(c) Stable level of SME finance relative to previous years
(d) No information on trend in SME finance relative to previous years
(e) Slight decline in SME finance relative to previous years or no
information on year-on-year trend
(f) No evidence of SME finance or significant year-on-year decline
• Keyword(s):
- Scoring
o Sector-leading growth in SME finance relative to previous
years – More than 15% of growth ratio (e.g., 2,000 (in
FY2022) – 1,500 (in FY2021) / 1500 = 33%
o Significant growth in SME finance relative to previous
years – +5% to +15% of growth ratio
o Stable level of SME finance relative to previous years - -5%
to +5% of growth ratio
o No information on trend in SME finance relative to previous
years - No year-to-year comparison of SME lending or
incomparable data (unable to calculate growth, only
absolute number)
o Slight decline in SME finance relative to previous years or
no information on year-on-year trend - 5% to 15% decrease
oNo evidence of SME finance or significant year-on-year

decline - More than 15% of decrease or no evidence of SME
loans
- Provide internal notes regarding the score provided.
- Expect changes from Content Team based on their analysis.

Industry Guidelines

- Procedure:
become irrelevant.
Business to underserved communities (est. %)

• Definition:
- Refers to percentage of lending business to disadvantaged
communities or underbanked customers.
- The definition of underserved communities, industry and country
contexts can be different -
o Business Specifics: The business itself is oriented for the
underserved communities, look at the percentage of its
business segment, and then give the credits (e.g., US:
Federal Agricultural Mortgage Corporation and Federal
National Mortgage Association)
- Underserved Communities per Industry
o Consumer Finance Industry: Students, new immigrants,
low-income individuals and household, rural dwellers,
women, and minority groups.
o Insurance: Migrant workers, low-income groups, and BEE
disclosures in South Africa
- Underserved Communities per Country
o India: ‘Priority Sector’ as defined by Republic of India
o US: take NOTES on Community Reinvestment Act (CRA)
lending – but will not immediately impact score
- Examples: Microloans, hardship loans, and other lending targeting

otherwise ignored or underbanked communities are included. We
also include hardship loans and disaster loans which typically
follow a large-scale event (i.e., tsunami or earthquake) or provide
cushions for existing customers who have temporary liquidity
issues due to life events (i.e., sudden health issues or
unemployment).
• Keyword(s):
‘rural loans’, ‘rural lending’, ‘hardship’, ‘disaster loan’, or ‘disadvantaged’,
‘indigenous’
- Sum the annual loans provided to these groups and divide by total
loans.
- Leave blank instead of updating to zero.
- Do not consider agriculture loans.
Industry Guidelines
Evidence of business to underserved communities (incl. rural

development, microfinance)
• Definition: Refers to the assessment of company’s business to
underserved communities (incl. rural development, microfinance)
• Keyword(s):
‘rural loans’, ‘rural lending’, ‘hardship’, ‘disaster loan’, or ‘disadvantaged’,
‘indigenous’
(a) Global leader in terms of business targeting underserved communities
(b) Above-average level of business targeting underserved communities
(c) Average level of business targeting underserved communities
(d) Below-average level of business targeting underserved communities
(e) No evidence of business targeting underserved communities
- Underserved Communities samples but not limited to women,
disabled, elderly population, ethnic minorities, low-income groups,
immigrants, students, entrepreneurs
- Scoring
o Global leader in terms of business targeting underserved

communities – More than 40% of revenues serving to
financially underserved demoparties
o Above-average level of business targeting underserved
communities – At least, 10% to 40% of revenues serving to
financially underserved demoparties
o Average level of business targeting underserved communities
– At least, 1% to 10% of revenues serving to financially
underserved demoparties
o Below-average level of business targeting underserved
communities – Less than 1% of revenues serving to financially
underserved demoparties

Industry Guidelines
Extent of involvement in Microfinance/Microinsurance

• Definition: Refers to any microfinance products offered or supported by
the institution.
(a) Direct provider or direct involvement in provision of services
(b) Partnership with or delegation to micro-finance institutions
(c) Wholesale financing and/or investment vehicles and/or securitization
(d) Charitable giving
(e) No information
• Keyword(s):
‘microfinance’, ‘micro’, ‘microinsurance’, ‘microloan’, and ‘microcredit’
- Scoring
o Direct provider or direct involvement in provision of services –
Includes direct provision of microfinance services through
majority-owned subsidiary or through core business
o Partnership with or delegation to micro-finance institutions –
includes both financial AND technical support for microfinance
institutions
o Wholesale financing and/or investment vehicles and/or
securitization – Includes indirect forms of support for
microfinance institutions, including wholesale financing
(lending, debt, equity investment etc.), financing through

investment vehicles (e.g., setting up a ‘microfinance fund’),
provision of financial services (e.g., securitization)
o Charitable giving – Includes anything from foundation, any
donations (money or in kind)
Innovation in Mobile / Online Distribution Channels

• Definition: Refers to any innovation in mobile / online distribution of the
company
(a) Sector leading innovation in mobile/online distribution targeting
underserved demographics
(b) Innovation in mobile/online distribution targeting underserved
demographics
(c) Mobile/online distribution with some focus on targeting underserved
demographics
(d) Mobile/online distribution but no information on distribution targeting
(e) Limited or no evidence of mobile/online distribution
• Keyword(s):
‘mobile’, ‘online’, ‘distribution channels’
- Banks: Key is whether company is explicitly using this strategy to reach
new underbanked markets, rather than just serving core markets.
- Insurance: Look for online platforms/mobile apps that allow
customers to buy insurance products or submit claims.
- Scoring:
o Sector leading innovation in mobile/online distribution
targeting underserved demographics – At least four
innovations in mobile/online distribution channels. Clearly
identified and targeted to underserved demoparties (e.g.,
women, disabled, elderly population, ethnic minorities, low-
income groups, immigrants, students, entrepreneurs)
o Innovation in mobile/online distribution targeting
underserved demographics - At least three innovations in
mobile/online distribution channels, clearly identified and
targeting to underserved demoparties.
o Mobile/online distribution with some focus on targeting
underserved demographics – At least one to two
innovations in mobile/online distribution channels, clearly
identified and targeting to underserved demoparties.
o Mobile/online distribution but no information on

distribution targeting underserved demographics – At
least evidence of innovations in mobile/online distribution
channels, but no information on distribution of targeting
underserved demoparties.

China A
- Sub-Industry: Diversified Banks, Regional Bank, Thrifts & Mortgage
Finance
- Default Scoring: Mobile/online distribution but no information on
distribution targeting underserved demographics
Industry Guideline
- Sub-Industry: Supranational and Insurance Broker
- Specific Guidelines:
o Should be No Value
Reach of Points Service (Branches, ATMs, Self-Service, etc.)

• Definition: Indicates the extent to which companies are offering alternative
distribution channels (e.g., branches/self-services) to its customers
(a) Global leader in branch/self-service/alternative distribution channels
(b) Regional leader in branch/self-service/alternative distribution channels
(c) Average level of branch/self-service/alternative distribution channels
(d) Regional laggard in branch/self-service/alternative distribution
channels
(e) Limited or no evidence of branch/self-services/alternative distribution
channels
• Keyword(s):
‘ATM’, ‘branches’, ‘self-service’
- Banks: Look for # of points of service, self-service channels, etc. Most
companies will score ‘average’ but those with broad reach can do better
(regional leaders).
- Default Scoring if there’s evidence found: Average level of branch/self-
service/alternative distribution channels
- Scoring:
o Global leader in branch/self-service/alternative
distribution channels - More than 40,000 total number of
combined (branches, ATMs and self-services) point of
financial services
Regional
o leader in branch/self-service/alternative
distribution channels - At least 20,000 to 40,000 total
number of combined point of financial services
o Average level of branch/self-service/alternative
distribution channels - At least 5,000 to 20,000 total
number of combined point of financial services
o Regional laggard in branch/self-service/alternative
distribution channels – At least 1,000 to 5,000 total number
of combined point of financial services
o Limited or no evidence of branch/self-services/alternative
distribution – Less than 1,000 total number of combined
point of financial services or no evidence/limited
information
- The numbers above are referred as for global banks. We recognize the
size bias of this datapoint. Though we would consider the wording
change in the model enhancement, please use your own understanding
and ask the market experts for smaller and/or emerging market banks
in the meantime.

Industry Guideline
- Sub-Industry: Supranational, Insurance Broker
Innovation in Other Alternative Branchless Distribution Channels (e.g.

correspondents, partnerships with retail stores/post offices)
• Definition: Refers to the innovation in other alternative branchless
distribution channels.
(a) Sector leading innovation in alternative branchless distribution
channels targeting underserved demographics
(b) Innovation in alternative branchless distribution channels targeting
(c) Alternative branchless distribution channels with some focus on
targeting underserved demographics
(d) Evidence of alternative branchless distribution channels but no
information on distribution targeting underserved demographics
(e) Limited or no evidence of alternative branchless distribution channels
- Includes any of the following:
Bancassurance to reach those not otherwise served in this way,

o
such as via rural banks
o Innovative retail distribution channels, such as partnerships
with supermarkets or small local retails to sell banking products
alongside consumer goods
o Partnership with NGOs
o Partnership with national or local government bodies / agencies
/ post offices
o Training sales staff to access new markets such as rural areas,
as is often the case for microfinance
o Mobile banking units that travel to remote regions
- Scoring:
o Sector leading innovation in alternative branchless
distribution channels targeting underserved demographics
– At least four of alternative branchless distribution
channels. Clearly identified and targeted to underserved
communities (e.g., women, disabled, elderly population,
ethnic minorities, low-income groups, immigrants, students,
entrepreneurs)
o Innovation in alternative branchless distribution channels
targeting underserved demographics – At least three
alternative branchless distribution channels. Clearly
identified and targeting to underserved demoparties.
o Alternative branchless distribution channels with some
focus on targeting underserved demographics – At least
one to two alternative branchless distribution channels.
Clearly identified and targeting to underserved
demoparties.
o Evidence of alternative branchless distribution channels
but no information on distribution targeting underserved
demographics – At least an evidence of alternative
branchless distribution channels, but no information on
distribution of targeting underserved demoparties.
Industry Guideline
- Sub-Industry: Supranational
Access to Healthcare
for growth and protecting their license to operate through efforts to improve access
to health care in developing countries and underserved markets. Scores are based on
exposure to underserved geographies; access to health-care strategy; and programs
in areas such as R&D, pricing, and licensing.
Company Expansion/Access Strategy

Company has plans to expand to emerging markets/developing countries
Definition: Indicates if company has plans to expand to emerging markets /
developing countries.
(a) Targets/strategy to expand in EMs beyond current operations
(b) Targets/strategy to improve/expand only in its current markets
(c) General statement on expansion
(d) No details on nature or countries of expansion
(e) No expansions plans to EMs detected
• Keyword(s):
‘expansion’, ‘emerging market’
- You may refer to this Scope – Market above for the list of countries
under the emerging/developing category
- This describes the expansion plan of company to emerging
markets/developing countries. Choose the option that best describes
the disclosure.
- Any evidence which states that the company has plans to expand its
facilities or reach in the developing markets. Example: Vietnam, China,
etc.
- Scoring:
o General statement on expansion – Select this for
companies that are already residing in developing countries
but have not disclosed any expansion plan
Presence in emerging markets via direct operations or majority-owned

subsidiaries
• Definition: Indicates the presence in emerging markets via direct
operations or majority-owned subsidiaries.
(a) Yes
(b) No
• Keyword(s):
- You may refer to this Scope – Market above for the list of countries
under the emerging/developing category
- Check if the company has its presence (in the form of manufacturing
facilities/approved medicines for sale) in the developing markets.
- Direct operations/regularly owned (more than 50% ownership)
subsidiaries in emerging markets/developing countries.
Extent of access to healthcare strategy in EMs/developing countries

• Definition: Pertains to the extent of access to healthcare strategy in
EMs/developing countries
(a) Vaccines
(b) On- patent medicines
(c) Off-patent medicines (generics/branded generics)
(d) Medical devices/diagnostics
(e) Combination of the above
• Keyword(s): patent, vaccine, medical devices, emerging markets,
donation
- This provides information the extent of access to healthcare strategy
in EMs/developing countries. Choose the option that best describes
the access to healthcare strategy that the company has.
Management system to implement and monitor its Access to

Healthcare strategy
Board level representation for Access to Healthcare issues
• Definition: Indicates if the company has a management system (i.e., board
level) to implement and monitor its Access to Healthcare strategy.
(a) Yes
(b) No
(c) Not Disclosed
• Keyword(s):
‘issues’
- Score ‘Yes’ if the company is included in Access to Medicines Index or
if the company explicitly discloses it elsewhere.
- Select “Not Disclosed” if no information is available
- Check if there is any oversight of a Board level committee over access

to healthcare related issues.
CSR or other committee oversees Access to Healthcare issues

• Definition: Indicates if the company has a management system (i.e., CSR
or other committee) to implement and monitor its Access to Healthcare
strategy.
(a) Yes
(b) No
(c) Not Disclosed
• Keyword(s):
‘board’, ‘CSR committee’,
- Score ‘Yes’ if the company has CSR or other committee oversees
Access to Healthcare issues or implement and monitor its Access to
Healthcare strategy.
Company’s disclosure of its Access to Healthcare-related

lobbying activities includes the following
Note: Please note that the entire section should not be scored for companies that
make ONLY generic drugs]
Explicit support of generic competition

• Definition: Indicates whether the company has publicly expressed support
of the entry of generics in the market to increase affordability of products
that treat diseases within scope
(a) Yes
(b) No
(c) Not Disclosed
• Keyword(s):
‘generic competition’, ‘generics’
- Only fill in if the company is NOT a generics manufacturer. Otherwise
leave as No Value.
- Diseases within scope include the top ten diseases in the world by
Disability Adjusted Life Year burden, orphan diseases and Neglected
Tropical Diseases
Explicit support of entire Doha Declaration on TRIPS

• Definition: Indicates if the company has an explicit support of entire Doha
Declaration on TRIPS
(a) Yes
(b) No
(c) Not Disclosed
• Keyword(s):
‘Doha Declaration’ ‘ TRIPS’, ‘intellectual property’
- The Doha Declaration affirms that "the TRIPS Agreement does not and
should not prevent Members from taking measures to protect public
health". This is a re-affirmation of the right of WTO Members to make
full use of the safeguard provisions of the TRIPS Agreement in order to
protect public health and enhance access to medicines for poor
countries.
- The Doha Declaration refers to several aspects of TRIPS, including the
right to grant compulsory licenses and the freedom to determine the
grounds upon which licenses are granted, the right to determine what
constitutes a national emergency and circumstances of extreme
urgency, and the freedom to establish the regime of exhaustion of
intellectual property rights.
General support of the Doha Declaration on TRIPS, with exceptions

• Definition: Indicates if the company has general support of the Doha
Declaration on TRIPS, with exceptions or reservations.
(a) Yes
(b) No
(c) Not Disclosed
• Keyword(s):
‘Doha Declaration’
- Only fill in if the company is NOT a generics manufacturer. Leave at no
value if the company is generics manufacturer. This data point is
usually, ‘No’. Only a few companies support the Doha Declaration.
Those who do support, will likely support with exceptions.
Lobbying on compulsory licensing

• Definition: Indicates if the company has lobbying on compulsory licensing
(a) Yes
(b) No
(c) Not Disclosed
• Keyword(s):
value if the company is generics manufacturer.
- Compulsory licensing is when a government allows someone else to
produce the patented product or process without the consent of the
patent owner. It is one of the flexibilities on patent protection included
in the WTO’s agreement on intellectual property — the TRIPS
Agreement (usually done in public health crisis,
o For example: In 2004, Malaysia issued a compulsory license
for HIV/AIDS medicines )"
Lobbying on trade imports

• Definition: Indicates if the company supports of parallel importation. Trade
imports refer to the imports of lower priced products from other countries
when the same product is available at a higher price in the importer's
market
(a) Yes
(b) No
(c) Some Evidence
• Keyword(s):
‘trade imports’
value if the company is a generics manufacturer.
Pricing transparency in developed and developing markets

Pricing transparency in developed and developing markets
• Definition: Pricing transparency in developed and developing markets
(a) Company discloses de-aggregated, absolute (e.g., USD/dose) time
series pricing date for all core products and dosage forms across all
markets (developed and developing) in which it operates
(b) Company discloses de-aggregated, absolute (e.g., USD/dose) pricing
data for some products
(c) Company discloses de-aggregated, relative (e.g., annual % change)

pricing data for some products
(d) Company discloses limited, aggregated pricing data (e.g., average
price/dose across disease class) for a limited number of products
(e) No or minimal disclosure on product pricing but some evidence to limit
price increases
(f) No transparency on product pricing
• Keyword(s):
pricing, developed market, average price
- VERY important indicator: Specify anything you find in internal notes
field and source.
- This is an aspirational indicator; many companies will not disclose but
we want to track those that are ahead of the game.
- If company discloses pricing information for ANY product (in
developed or developing countries), give credit.
- No Value if there are no commercialized products in the market.
China A
- Specific Guidelines: For Chinese company which has product on the
NRDL list, check if the company discloses the prices on its own website
and then give credit
Equitable pricing policies for products and services in

developing countries
Scope of equitable pricing policies, inter- and intra-country
• Definition: Indicates whether the company implements tiered pricing for its
products between countries, within countries or on both levels. With tiered
pricing, the price of products is tailored according to the ability to pay both
between and within countries. This applies to patented drugs, generics,
vaccines, and medical devices.
(a) Inter-country AND intra-country tiered pricing based on affordability
(b) Inter-country OR intra-country tiered pricing based on affordability
(c) Limited or general pricing policy based on affordability
(d) No evidence of pricing mechanisms based on affordability
• Keyword(s):
pricing, developed market, developing countries
- Inter-country vs Intra-country
Inter-country – between different countries

o
Intra-country– between different affordability segments of
o
the same country
- Unlikely to find except for some of the bigger companies.
- Check Access to Medicine Index to make sure for the bigger
companies (e.g., GSK, Merck etc.).
- Pricing strategies that lack evidence of a clear affordability rationale
and/or are not clearly and specifically targeted toward a relevant (low-
income) population segment are excluded.
- No Value if there are no commercialized products in the market
China A
- Specific Guidelines: If Chinese companies have products on the China
National Reimbursement Drug List (NRDL), they should be given credit.
Scope of equitable pricing policies, by product

• Definition: Indicates the number of products with equitable pricing policy.
(a) Equitable pricing policy for 5 or more products
(b) Equitable pricing policy for 3-4 products
(c) Equitable pricing policy for 1-2 products
(d) No equitable pricing policy
• Keyword(s):
price, pricing
- Unlikely to find except for some of the bigger companies. Score ‘No’ if
there is no relevant product on the market.
- Check Access to Medicine Index to make sure for the bigger
companies (e.g., GSK, Merck etc.).
- Pricing strategies that lack evidence of a clear affordability rationale
and/or are not clearly and specifically targeted toward a relevant (low-
income) population segment are excluded
- No Value if there are no commercialized products in the market
China A
- Specific Guidelines: China NRDL list included products are all counted,
if far more than 5, the score should be given based on the indications
that drugs used for.
Engagement in Non-exclusive voluntary licensing

Note: Do not score this section for companies that make only generic drugs
Non-exclusive voluntary licenses (NELVS) are licenses that are granted non-
exclusively and allow the manufacture and supply of generic versions of patented
medicines by other manufacturers.
Not applicable to licenses granted with the objective of market entry in various
countries.
Number of non-exclusive voluntary licenses/products

• Definition: Indicates the number of non-exclusive voluntary licenses
voluntary licenses/products.
(a) Non-exclusive voluntary licensing for 5 or more products
(b) Non-exclusive voluntary licensing for 3-4 products
(c) Non-exclusive voluntary licensing for 1-2 products
(d) None
• Keyword(s):
non-exclusive voluntary license
- Generally, only larger companies will issue non-exclusive voluntary
licenses (e.g., GSK, Merck & Co.). Also check Access to Medicine Index
company profiles.
- No Value if there are no commercialized products in the market and for
generic-only companies
Number of non-exclusive voluntary licenses with quality checks

• Definition: Indicates the number of non-exclusive voluntary licenses
with quality checks.
(a) More than 10 active non-exclusive voluntary licenses with pre-
manufacturing quality checks, 5 to 10 active non-exclusive voluntary
licenses with pre-manufacturing quality checks
(b) Fewer than 5 active non-exclusive voluntary licenses with pre-
manufacturing quality checks
(c) Blanket waiver of patent rights (non-assert declaration) with pre-
manufacturing quality checks
(d) Exclusive voluntary licensing with pricing controls on the licensee
(e) None
• Keyword(s):
quality check, audit, non-exclusive voluntary license

- Generally, only larger companies will issue non-exclusive voluntary
licenses (e.g., GSK, Merck & Co.). Also check Access to Medicine Index
company profiles.
- No Value if there are no commercialized products in the market and for
generic-only companies
Company is involved in these capacity advancement initiatives

in developing countries
Involvement in capacity advancement initiatives in developing countries
towards improving pharmaceutical supply chains
• Definition: Indicates the company contribution in capacity advancement
initiatives in developing countries towards improving pharmaceutical
supply chains.
(a) Yes
(b) No
(c) Not Disclosed
• Keyword(s):
‘supply chain’, ‘affordability’ ‘accessibility’, ‘index disease products’
- Company's efforts for better reach of its medicines in developing
countries.
- The company is engaged in programs and partnerships aimed at
improving pharmaceutical supply chain capacity in the developing
Countries with the aim of improved affordability, accessibility, and
quality of the delivered Index Disease Products.
- Innovative techniques for supply temperature sensitive products.
- Examples include providing help in establishing cold chains and in
introducing processes or technologies which can help prevent drug
diversion or counterfeiting in the developing Countries.
o WHO Good Distribution Practices
o Technologies and process to prevent counterfeiting
o Differential pricing of between high, middle, and low-income
markets, however, has raised complicated economic, legal,
and supply chain challenges.
Involvement in capacity advancement initiatives in developing countries

towards supporting local R&D capacity through PPPs
• Definition: Indicates the company contribution in capacity advancement
initiatives in developing countries towards supporting local R&D capacity
through public-private partnerships (PPPs).
(a) Yes
(b) No
(c) Not Disclosed
• Keyword(s):
Research and development, R&D, public-private partnerships, PPP
- Answer the following questions
o Is there evidence that the company participates in public-
private partnerships in the developing Countries with the
aim of increasing local capacity for research?
o Does the company support the research carried out by Index
Countries' academic institutions?
- The company has introduced innovative (unique in the sector)
approaches to working with the developing country organizations
which help improve the local research capacity for the developing
country diseases.
- Types of PPP
o PPP funded as philanthropy
o Some MNC’s are working alone but with a view to
subsequent partnering
o Commercial partnerships
o Companies with limited in-house expertise/interest in
neglected disease
Support for post-market surveillance

• Definition: Indicates whether the company supports initiatives to build
capacity to improve pharmacovigilance capability (i.e., monitoring the
effects of drugs after sale to identify and evaluate previously unreported
adverse reactions) in developing countries
(a) Yes
(b) No
(c) Not Disclosed
• Keyword(s):
Pharmacovigilance, post-market surveillance, vigilance, adverse events

- Companies usually do not disclose this, but most companies have this,
type in search terms like "vigilance", "post-market surveillance",
"adverse events" into the company's website search function and CSR
reports.
- The company commits to support the implementation of
pharmacovigilance systems in the developing countries.
- The company discloses details regarding its activities related to
establishing pharmacovigilance systems in the developing countries.
- The company actively engages in establishing and supporting
pharmacovigilance-related programs in the developing countries
during the analysis period.
- Capacity building of Pharmacovigilance
o Structures, systems
o Staff and infrastructure
o Skills
o Tools
Assistance to local manufacturers to achieve international drug

manufacturing standards (e.g. WHO GMP)
• Definition: Indicates if the company assists local manufacturers to achieve
international drug manufacturing standards (e.g., WHO GMP)
(a) Yes
(b) No
(c) Not Disclosed
• Keyword(s):
local manufacturers, manufacturing standards, GMP, good manufacturing
practices
- Answer the question, ‘Is there evidence that the company assists local
licensees or contract manufacturers to achieve international drug
manufacturing standards (such as FDA, EMA or the WHO Good
Manufacturing Practices) in the developing Countries?’
- The company has introduced innovative (unique in the sector)
approaches to working with the developing Country organizations to
improve the quality and accessibility of the products for Index
Diseases, in areas such as countering drug diversion, counterfeiting
and local quality management.
- Check if the company provides any kind of technical or other

assistance to local manufacturers to achieve required standards. This
could be in the form of training/seminars.
- GMP vs Drug Quality
o GMP shows that a manufacturing facility is capable of
making products properly and consistently; it does not
demonstrate that the drugs produced contain the correct
active ingredient in the right proportions and that they work
as intended
• Active Ingredient
• Excipient
• Formulation
• Packaging or repackaging
Training of local healthcare workers

• Definition: Indicates whether the company undertakes initiatives to
train health care workers in developing countries to strengthen the
existing health system and build local capacity
(a) Yes
(b) No
(c) Not Disclosed
• Keyword(s):
training, education, seminar
- More likely to be "yes" than other capacity advancement initiatives like
improving pharmaceutical supply chains and supporting local R&D via
PPPs (public-private partnerships), but still overall rare for smaller
companies.
Involvement in capacity advancement/increasing public health in

developing countries
• Definition: Indicates whether the company undertakes initiatives to
improve public health and strengthen the local health system in developing
countries. These initiatives aim to address local needs and skill
requirements, in collaboration with relevant stakeholders, and may have
long term sustainability aims.
(a) Yes
(b) No
(c) Not Disclosed

• Keyword(s):
capacity advancement, public health
- Check if the company conducts any kind of workshops/seminars in
developing countries to raise public awareness. Common examples
are that of public awareness campaigns for eradication of Malaria.
- More likely "yes" than other capacity advancement initiatives like
improving pharmaceutical supply chains and supporting local R&D via
PPPs (public-private partnerships), but still overall rare for smaller
companies.
- Any activities that exclusively help the companies’ own local operations
and cannot be expanded in a systematic manner to accessing other
products do NOT count
Addresses diseases, orphan drugs

Scope of disease/ orphan drugs available on the market
• Definition: Indicates the estimated number of products (that the company
has on-market) that treat the top ten diseases in the world by Disability
Adjusted Life Year burden, orphan diseases and Neglected Tropical
Diseases.
(a) Products in 5 or more disease areas
(b) Products in 3-4 disease areas
(c) Products in 1-2 disease areas
(d) No products in these disease areas
• Keyword(s):
orphan drug
- Only for relevant products on the market (compounds in R&D phases
do not count here)
- Orphan Drug Links:
o US FDA
o Europe Orphanet
o Europe Orphanet Report
o For all other countries, please run a general google search.
- Global causes of DALY:
https://www.who.int/data/gho/data/themes/mortality-and-global-
health-estimates
- No Value if there are no pharmacovigilance commercialized products

in the market
Scope of disease/ orphan drugs R&D

• Definition: Indicates the number of drug candidates in the company's
pipeline that address the top ten diseases in the world by Disability
Adjusted Life Year burden, orphan diseases and Neglected Tropical
Disease.
(a) Ongoing R&D in 5 or more disease areas
(b) Ongoing R&D in 3-4 disease areas
(c) Ongoing R&D in 1-2 disease areas
(d) No ongoing R&D in these disease areas
• Keyword(s):
research and development, R&D, orphan drug
• Global causes of DALY:
https://www.who.int/data/gho/data/themes/mortality-and-global-
health-estimates
- Only for relevant products in R&D clinical trial phases I, II, and III
- Products already on the market/available to consumers/patients do
not count here.
Antibiotic Resistance Risk in developed and developing

markets
Has the company acknowledged resistance to antibiotics as a public
health risk theme?
• Definition: Indicates whether the company publicly acknowledges the
public health risks resulting from indiscriminate antibiotic use
(a) Yes
(b) Some Evidence
(c) Not Disclosed
• Keyword(s):
- This KPI applies to all companies scored on the ATH KI – medical
device companies, biotech, pharma etc. All different products count
including vaccines, diagnostics, and traditional drugs/biologics.
- Companies that are official signatories to the Davos Declaration

automatically get credit.
o Access Declaration by the Pharmaceutical, Biotechnology
and Diagnostics Industries on Combating Antimicrobial
Resistance
o Check for the ‘Read the industry declaration’ section.
o Check the ‘Signatories’ section at the bottom. If the
company is on the list, score ‘Yes’
- Companies that are not official signatories but state that they support
the Davos Declaration (e.g., on their website or in policy statements
also get credit), score this data point as ‘Yes’
Is the company conducting R&D to address antibiotic resistance (e.g., in-

house R&D, partnerships)?
• Definition:
Indicates if the company conducts R&D (alone or via collaborations)
to address antibiotic resistance
(a) Yes
(b) No
(c) Some Evidence
• Keyword(s):
antibiotics/antimicrobial resistance, MRSA, superbugs
- In-house R&D - Research done by the company for discovering new
drugs
- Companies that are official signatories to the Davos Declaration
automatically get credit (select ‘yes’). Visit: https://amr-
review.org/industry-declaration.html and check the company list in the
industry declaration section.
- Companies that are not official signatories but state that they support
the Davos Declaration (e.g., on their website or in policy statements
also get credit (select ‘yes’).
- Partnerships such as with NIH, Wellcome Trust, government, and
academia count, as well as in-house R&D
Scope of product donations in developing countries targeting Access to

Healthcare
• Definition: Indicates the company’s scope of product donations in
developing countries targeting access to healthcare
(a) 5 or more long-term single drug donation programs
(b) 3-4 long-term single drug donation programs
(c) 1-2 long-term single drug donation programs
(d) Short-term donation programs (based on availability) or disaster relief
geared to address developing country needs
(e) Limited donation programs (anecdotal evidence only)
(f) No donation programs
• Keyword(s):
donation, single drug
- We really want to distinguish long-term product donation programs
(which are a positive thing and companies SHOULD be given credit for)
and which are based on the NEEDS of people vs. companies that are
"dumping' products in lower -income countries (i.e., dumping expired or
nearly expired products, or products that people don't specifically need
and that are just going to waste/landfills).
- The company commits to make its best efforts to assure the donated
products are administered to patients in the target Country.
- Company’s process in donation, PPPs for ensuring the donations to
reach patients
- The company publicly discloses detailed information about the type,
volume, and destination of the donated products in the Index Countries.
- Single Drug Donations - typically need-driven targeted programs with a
defined strategy as to the type, volume, and destination of donated
products. These may be programs oriented toward specific disease
elimination. Most relevant for neglected tropical diseases.
- Scenarios of Drug Donations
o Donations directly from pharmaceutical companies
o Donations indirectly through private voluntary organizations
o In the form of aid through governments
o Donations directly at single health‐care facilities
- Unique in Sector Approach - Example: Pfizer Colleagues Partnered in
All Facets of the Relief Effort in Tsunami, Sri Lanka
o Search & rescue
o Planning
o Strategy
o Supply distribution
What is the company's status with regard to Medicines Patent

Pool (MPP)?"
Medicines Patent Pool (MPP)/Explicitly entered into licensing contract
• Definition: Indicates if the company has Medicines Patent Pool (MPP) or
explicitly entered licensing contract
(a) Signed licensing agreement with MPP for 5 or more products
(b) Signed licensing agreement with MPP for 3-4 products
(c) Signed licensing agreement with MPP for 2 products
(d) Signed licensing agreement with MPP for 1 product
• Keyword(s):
Medicines Patent Pool, MPP, licensing contract
- Only fill in if the company is NOT a generics manufacturer (if qualifies
(not a generics manufacturer), is often 'no')
- Do not score if the company does not have products to treat HIV/AIDS,
Hep C, and malaria
Medicines Patent Pool (MPP)/Geographic scope of licensing contracts

• Definition:
Indicates if the company sets limits to the geographic scope of
contracts with MPP.
(a) Broad geographic scope of license including both Least Developed
Countries and Middle Income Countries
(b) Company sets limits to geographic scope (e.g. excludes Middle Income
Countries)
• Keyword(s):
Medicines Patent Pool, MPP, licensing contract
- Leave blank if company has not signed licensing agreement with MPP.
Biodiversity & Land Use

This key issue evaluates the extent to which companies may face lost market access
or litigation, liabilities, or reclamation costs due to operations that damage fragile
ecosystems. Scores are based on operations involving land disturbance and in
regions with fragile ecosystems; policies/programs regarding biodiversity, land use,
and community impact; and controversies.
Policies & Disclosure

Clear targets with regard to land use
• Definition: This data point evaluates whether the company has clear
targets related to its use of land.
a) Yes
b) No
c) No evidence
• Keyword(s):
target, land use
- Scoring:
o Yes - Select this option if the company has clear targets for
land use.
• Land use targets should be specific, measurable,
quantitative
• This does not include qualitative statements or
commitments of operating in conjunction with
communities nor does quantitative numbers
reporting count.
• We want the companies to state that they have a
goal of reclaiming x% of land per year, etc.
o No - Select this option if the company does not have targets
for land use. A target for trees planted does not count.
o Not Disclosed- No information available.
Industry Guidelines
- Sector: Utilities
- Default Scoring: leave data point as "No Value”
- Sector: Agricultural Products

- Specific Guidelines: Score “Yes”, if the company has quantitative
and timebound target for external certification to recognized
standards (e.g. RSPO), Zero deforestation target by a certain date.
Does the company work with credible external stakeholder groups to verify
it's sustainable practices?
• Definition: This data point evaluates whether the company has
partnerships with external stakeholder groups. Note that partnership must
be related to biodiversity/environmental activities.
a) No evidence of membership or certification related to managing
biodiversity and land use risks
b) Some partnership but no commonly accepted or stringent standards
(i.e. work with a university)
c) Membership in or partnership with industry group or external
organization at the local level (including environmental regulators)
d) Verification by internationally recognized highest standards for
industry
• Keyword(s):
partner, external, verification, evaluate
- We are not looking for certifications or commitments, we are looking
for procedural development.
- DO NOT consider ISO 14001 for this data point as it does not explicitly
include biodiversity.
- Scoring:
o No evidence of membership or certification related to
managing biodiversity and land use risks – Select this
option if the company has no memberships or partnerships
with any credible external stakeholders.
o Some partnership but no commonly accepted or stringent
standards (i.e. work with a university)
o Membership in or partnership with industry group or
external organization at the local level (including
environmental regulators) — Select this option if the
company has a membership in or partnership with industry
groups, local external organizations, and/or environmental
regulators
o Verification by internationally recognized, highest
standards for industry – Select this option if the company
is part of an international organization with high standards
for its industry.
•
Example: A company working with the World Wildlife
Foundation at their Brazilian mines to establish
biodiversity conservation practices specific to that
location.
Industry Guidelines
- Sector: Agricultural Products
o Look for information on internal and/ or third-party
verification processes; strong efforts and performance
including proper management of agrochemicals, reducing
wood consumption, wastewater treatment systems, and
reforestation programs.
- Scoring:
environmental regulators) - Good Agricultural Practices
(GAP) audits and/or membership to RSPO should be scored
standards for industry – Palm oil producers with palm oil
volumes certified to RSPO's segregated and identity-
preserved schemes.
- Sector: Metals & Mining

o Score if the company is working with biodiversity groups on
a specific project and not merely cooperating with an all-
encompassing generic policy.
o Mere memberships in the International Council on Mining
and Metals (ICMM), UN Global Compact, ISO, etc would not
be considering here.
- Sector: Paper and Forest Products

environmental regulators) - IF the company is a member of
SFI (Sustainable Forestry Initiative) and/or PEFC
(Programme for the Endorsement of Forest Certification).
- Sector: Paper and Forest Products, Utilities
standards for industry – if company has partnerships with
or membership in any of the following: WWF, Fauna and
Flora International, UN Environment Programme, Nature
Conservancy, IUCN, FSC
Scope of the industry or international standard used

• Definition: This data point evaluates the extent of the company’s
partnerships with external stakeholder groups.
a) Covers more than 90% of operations or products
b) Covers 70% to 90% of operations or products
c) Covers 30% to 70% of operations or products
d) Covers less than 30% of operations or products
e) Not disclosed
• Keyword(s):
partner, external, verification, evaluate
- This data point pertains to the scope of the previous data point, “Does
the company work with credible external stakeholder groups to verify it's
sustainable practices?”
- Select how much of the company's operations are partnered with
external groups.
o For example, if a company works with the WWF at 10% of
its sites but with other external groups at 40%, pick “Covers
30% to 70% of operations or products”
- Companies do not usually disclose specific numbers. We can however,
estimate based on the sites' % production in relation to the total
production volume of the company.
o For example, If a Brazilian mine represented say 40% of the
company’s overall production, then you would select the
option “Covers 30% to 70% of operations or products”
- Scoring:
o Covers more than 90% of operations or products
o Covers 70% to 90% of operations or products
o Covers 30% to 70% of operations or products
o Covers less than 30% of operations or products
o Not disclosed – No information available
Policies & Disclosure – Clear policy on

Policy includes provisions on sustainably managing natural resources and
raw materials
• Definition: This data point evaluates the company’s policies and programs
to sustainably manage and regulate the use of natural resources and raw
materials used by the company for its operations.
a) Yes
b) No
c) Not Disclosed
Keyword(s):
goal, target, commitment, policy, natural resources, water, eco, biodiversity
- Scoring:
o Yes – Select this option if the company has a
goal/target/commitment/policy.
• Sample disclosure we can consider OIL &GAS
industry: “The Crestwood Biodiversity Policy
contains provisions on respecting indigenous
peoples and minimizing community impacts as well
as sustainably managing natural resources and raw
materials.”
o No
o Not Disclosed – No information available.
Industry Guidelines
- Sector: Utilities
- Sector: Agricultural Products, specifically palm oil companies

- Default Scoring: Yes, IF the company has policies or a commitment
to No Deforestation, No Peat, No Exploitation (NDPE)
Minimizing disturbance from operations

• Definition: This data point evaluates the company’s efforts to minimize the
impact of its operations on the surrounding eco-systems, communities,
and natural habitat.
a) Yes
b) No
c) Not Disclosed
Keyword(s):
survey, community consultation, goal, minimize, target, reclaim,
biodiversity, water, land
- Scoring:
o Yes – Select this option if the company has a
goal/target/commitment/policy.
industry: “As a midstream oil and gas company, our
operations involve inherent risks of adversely
impacting the environment, such as temporarily
disturbing habitats during pipeline construction or
facility siting. To mitigate these risks, our design and
construction teams adopt engineering practices and
routing criteria to reduce our impact throughout a
project’s lifecycle, modifying pipeline routes and
workspaces in sensitive habitats to avoid or
minimize impacts. We also use biodiversity offsets
in areas where land disturbances are unavoidable.”
o No
Industry Guidelines
- Default Scoring: Yes, IF the company has policies or a commitment to
No Deforestation, No Peat, No Exploitation (NDPE)
Reclaiming habitat, disturbed land

• Definition: This data point evaluates the company’s policies and programs
to reclaim and rehabilitate habitat and disturbed land.
a) Yes
b) No
c) Not Disclosed
Keyword(s):
goal, target, commitment, policy, reclaim
- We do not consider conflict-related rehabilitation for this data point.
- Scoring:
Yes – Select this option if the company has a

o
goal/target/commitment/policy/land reclamation
program/community consultation.
o No
Industry Guidelines
- Sector: Utilities
Scope of biodiversity and land reclamation policy

• Definition: This data point evaluates the extent of company’s policies and
programs to reclaim land and biodiversity.
a) No clear scope or policy
b) Partial operations
c) All operations
d) All operations and the supply chain
Keyword(s):
goal, target, commitment, policy, reclaim
- Scoring:
o No clear scope or policy – No reclamation done by the
company.
o Partial operations – Reclamation present but not by all
operations.
industry: “The primary goal of reclamation on oil and
gas lands is to restore site stability and ecosystem
functions, returning disturbed lands to their original
use or use prior to disturbance, such as crop
production or wildlife habitat. The benchmark for
successful reclamation typically is the
establishment of a native plant community that is
self-sustaining and meets standards for density and
forage production, and the re-contouring of all
disturbed surface areas to match or blend with the
original landform. Shell has implemented a number
of environmental measures with the aim of
protecting local biodiversity, keeping air and water
clean, and reclaiming the land once drilling ends.”

(Royal Dutch/Shell PLC)
o All operations – Reclamation present in all operations.
o All operations and the supply chain - Reclamation present
in all operations AND supplier’s operations.
Industry Guidelines
- Sector: Utilities
Programs & Structures

Restoration or rehabilitation of disturbed areas with continuous operation
• Definition: This data point evaluates the extent of the company's efforts
regarding restoration or rehabilitation.
a) Concurrent restoration efforts occur at all operational sites
b) Concurrent restoration occurs at many operational sites
c) Restoration efforts only active at a few current operational sites
d) No
• Keyword(s):
restore, rehabilitate
- Scoring:
o Concurrent restoration efforts occur at all operational sites
– Select this option if ALL operations have active
restoration or rehabilitation projects.
o Concurrent restoration occurs at many operational sites –
Select this option if majority of operations have active
restoration or rehabilitation projects.
o Restoration efforts only active at a few current operational
sites – Select this option if evidence only shows that there
is a restoration or rehabilitation at SOME operational sites.
o No – No information available.
Industry Guidelines
- Guidelines: Mine closure plans CANNOT be considered for this
data point because it is already a requirement for mining
companies. Only look for restoration efforts being done while
operations are running.
- Sector: Utilities
Programs to protect natural ecosystems

• Definition: The data point refers to the programs/initiatives of the company
to protect the natural ecosystems where they conduct their operations like
preservation, creating reserves for wildlife, planting indigenous plants, etc.
a) No
b) Preservation is focused on only one species per location
c) Commits to planting indigenous vegetation at all reclamation sites
d) Reserves or develops areas under its control such as sensitive areas or
wetlands to preserve local species at major sites
e) Creates reservations, wetlands for protection and plants indigenous
vegetation at all major sites
• Keyword(s):
reserve, species, wildlife, indigenous, vegetation, preserve, wetland,
ecosystem
- Look for the programs/ initiatives on protecting natural ecosystem,
within the company’s area of operations.
- Scoring:
o No
o Preservation is focused on only one species per location –
Select this option if there is only preservation for a certain
species OR reforestation of a non-indigenous or otherwise
unclear vegetation/species per location.
o Commits to planting indigenous vegetation at all
reclamation sites – Select this option if there are
initiatives/efforts (e.g., reforestation) to plants indigenous
vegetation in reclamation sites.
o Reserves or develops areas under its control such as
sensitive areas or wetlands to preserve local species at
major sites – Select this option if there are
initiatives/efforts to develop wetlands or reserves to protect
local species on their major sites.
o Creates reservations, wetlands for protection and plants
indigenous vegetation at all major sites – Select this option
if there are efforts/initiatives to create reservation,
wetlands, and indigenous vegetation planting for all the
company's major sites. If the company does not abide by
everything in this dropdown option, it can’t be given this

scoring.
Industry Guidelines
- Sector: Utilities
- Default Scoring: Donations can be considered for this data point.
Programs & Structures – Biodiversity and community impact

assessment
Company conducts community impact assessment prior to settling in new
areas
regarding assessment of community and surrounding biodiversity.
a) Yes
b) No
c) Not Disclosed
• Keyword(s):
assess, impact, community, social, social impact assessment
- Policy documents can also be considered for this data point.
- Scoring: Commented [ACJ2]: Pending Content Team:
o Yes – Select this option if there is evidence that the
If there are policy documents (regulations for
company reaches out to communities near areas of community impact assessments) mandated by the
operation before starting their projects. This must be while government for each market. Do we consider this as
the company is still in the planning stage and not during “Yes”?
construction.
o No
Company conducts biodiversity impact assessment prior to settling in new

areas
a) Yes
b) No
c) Not Disclosed
• Keyword(s):
assess, impact, biodiversity, environmental, environmental impact

assessment
- Policy documents can also be considered for this data point.
- This is often scored for Oil & Gas and Mining companies.
- Scoring: Commented [ACJ3]: Pending Content Team:
o Yes – Select this option if there is evidence that company
If there are policy documents (regulations for
conducts biodiversity assessments in the area prior to biodiversity impact assessments) mandated by the
conducting operations. government for each market. Do we consider this as
o No “Yes”?
JP IMI
- Industry: All
- Source:
https://elaws.e-gov.go.jp/document?lawid=420AC1000000058
Performance
Oil Spills
• Definition: This data point pertains to the company's performance in terms
of Oil Spill.
N/A, tabular data point
• Keyword(s):
spills
- If no evidence for the year, don’t add a new row or leave a blank row.
- Input the amount of Oil Spill reported.
- The unit of measurement should be converted to cubic meters (m3).
Use this “Unit Conversion Factor” for conversion.
- Case #1: Sample Disclosure of IID000000002162049 - CIMAREX
ENERGY CO
o If the company disclosed recovered volumes of spills, we
would not subtract it from the volume of oil spill. We do
not collect a secondary datapoint on recovered volumes as
we consider the initial release.
o We can consider Hydrocarbon Liquid spills.
o Do not consider Produced Water Spills. Though produced
water spills have an adverse impact on the ecosystem,
currently very few issuers disclose data for produced water
spills. It can potentially be argued that the rate (volume)

and potentially time of containment/recovery can be
considered as management proxies but that needs to be
considered as a model revamp at a later stage and after
considering data availability.
o Do we consider both primary containment and secondary
containment? Primary containment is the receptacle in
which the hydrocarbon liquid is contained during normal
operation. It confines the substance and, when all goes
well, does not allow it to spill or leak outside of the
container. Secondary containment, on the other hand, is
intended to contain a spill or leak when the primary
containment fails. Unlike primary containment units,
secondary containment is not continuously filled with the
substance and only acts as a safeguard. No matter the
containment system used, please collect data for only
volume of hydrocarbon liquid spills if it is explicitly
reported (not a cumulative sum of the volume of
hydrocarbon and produced water spills).
IID000000002162049 - CIMAREX ENERGY CO - ESG Performance Data

Industry Guidelines
- Sector: Oil & Gas
- Guidelines: Must be scored for this industry ONLY.
Fresh Water Used

• Definition: This data point evaluates the company's commitment to
sustainable water management.
N/A, tabular data point

• Keyword(s):
freshwater
- Scoring:
o Input the total amount of fresh water consumed by the
company; be careful of this data point; data should be for
FRESHWATER CONSUMPTION and NOT for FRESHWATER
WITHDRAWAL.
o This data point must ALWAYS come from the same data
disclosed in the "Freshwater Consumption - Reported" data
point under Water Stress.
Industry Guidelines
- Sector: Utilities, Commodity Chemicals, Specialty Chemicals, Commented [ACJ4]: Pending Content Team:
Diversified Chemicals, Metals & Mining (Precious and Non Precious),
Guidance on Paper & Forest Products, Containers &
Steel Packaging
- Guidelines: DO NOT answer. Remove rows from Capture if
present/published.
- Sector: Industrials
- Guidelines: Only score if the company has a business segment
involved in a sector where Fresh Water Used is scored. Otherwise, DO
NOT answer Remove rows from Capture if present/published.
- Sector: Oil & Gas

o Must be scored for this industry ONLY.
o The unit of measurement should be converted to cubic
meters (m3).
o Use this “Unit Conversion Factor” for conversion.
Practices
Land use permits & agreements with local communities
• Definition: This data point evaluates whether the company has land
permits and agreements with local communities for their areas of
operation.
a) Secured at all locations
b) Secured for key projects
c) Secured at some locations
d) No evidence
e) Revoked
• Keyword(s):
land permit
- Check Environmental Policy, ESG Report, Sustainability Report, Annual
Report, or company website. US companies may have their land
permits listed on their website.
China A
- Background: In China, land is owned by the public, so no local
communities can claim that land belongs to them. Instead, the local
government administers land on behalf of the public.
- Specific Scoring Guidance:
o Secured at all locations – Only score if there is a clear
disclosure with clear indication of 100% operations
o Secured for key projects – Only score if there is a clear
disclosure with clear indication of the covered operations.
o Secured at some locations – Select this option in case of
no disclosure & no negative news reports/controversies on
land use or protest by local communities in the last 3
years.
o No evidence – Select if no disclosure & there are negative
news reports/controversies on land use or protest by local
communities in the last 3 years.
o Revoked – Rare, only if clear evidence.
Practices – Policies related to environmental impact

Scope of policies to minimize environmental impact of operations
• Definition: This data point evaluates the company’s policies to minimize
the impact of its operations on the surrounding eco-systems, communities,
a) Policies cover all relevant operations
b) Policies cover selected operations
c) General commitment to minimize environmental impact of operations
d) Minimum practices expected based on domestic industry norms
e) No evidence
• Keyword(s):
policy, policies, impact
- Answer if the company is China A issuer unless the issuer is Non-China

A then we must refer in Non-China A requirements document for
specific guidance.
- Scoring:
o Policies cover all relevant operations
o Policies cover selected operations
o General commitment to minimize environmental impact of
operations – There is no policy disclosed but the company
is committed to minimize the impact of its operations.
o Minimum practices expected based on domestic industry
norms
o No evidence – No information available.
China A
- Sub-Industry: All
- Default Scoring: Minimum practices expected based on domestic
industry norms
- Source:
o For Other
Environmental Protection Law
http://zfs.mep.gov.cn/fl/201404/t20140425_271040.htm
o For energy sector
Regulations on Environmental Protection and
Administration of Offshore Oil Exploration and Development
http://www.zhb.gov.cn/gzfw_13107/zcfg/fg/xzfg/201605/
t20160522_343314.shtml

Mineral Resources Law of the People's Republic of China

http://www.mlr.gov.cn/zwgk/flfg/kczyflfg/200406/t20040
625_292.htm
- environmental pollution control and minimization,
reclamation
o For Mining
The Supervision System for the Prevention and Control of
Soil pollution in Industrial and Mining Land, MEE, 2018
http://www.mee.gov.cn/gkml/sthjbgw/sthjbl/201805/t201
80510_438760.htm

625_292.htm
- environmental pollution control and minimization,
reclamation
Policy includes commitment to minimizing disturbance from operations

• Definition: This data point evaluates whether the company has
commitments to minimizing disturbance from their operations.
a) Yes
b) No
c) No evidence
• Keyword(s):
engagement, minimal, minimize, disturbance, mitigate, mitigation
- Scoring:
o Yes – Select this option if a company’s policy includes
provisions committed to minimizing disturbance to the
environment and affected local communities.
o No
China A Commented [ACJ5]: @Lo, Riza Anne
- Industry: All
o Often Not Disclosed. Rarely does a Chinese issuer have a
clear and public stated policy, instead it may have a such
commitment on the website or in the CSR.
o Score Yes if the commitment includes specific content for
the same. Otherwise, don’t give credit.
Policy includes commitment to reclaim habitat, disturbed land to pre-

disturbed conditions
• Definition: This data point evaluates the company’s policies to reclaim land
affected by its areas of operation to pre-disturbed conditions.
a) Yes
b) No
c) Not disclosed
• Keyword(s):
reclaim, pre-disturbed, reforestation, reclamation, restoration
- Scoring:
o Yes – Select if the company's policy includes a commitment
to reclaim affected habitat and land to its pre-disturbed
condition.
o No – Select if the company does not have any commitment
to reclaim affected habitat and land.
o Not disclosed – No related disclosure found.
norms
China A
- Sub-Industry: Metals and Mining; energy sector except Oil & Gas
Equipment & Services & Oil & Gas Storage & Transportation.
industry norms
- Source:
http://www.mlr.gov.cn/zwgk/flfg/kczyflfg/200406/t20040625_29
2.htm
reclamation is mandated for mines at end of life
Regulation for Eco-environmental Protection and Reclamation for
Mining
http://www.gov.cn/flfg/2009-03/05/content_1251130.htm
Practices – Areas of environmental impact mitigation activities

Company designates no-disturbance areas
a) Yes
b) No
c) No evidence
• Keyword(s):
no disturbance, zone, conserve, conservation, protect, protected
specific guidance
- For companies in the Agricultural Products industry, look for high-
conservation areas (HCAs) and high conservation value areas (HCVAs)
- Scoring:
o Yes – Select if the company designates no disturbance
areas.
o No – Select if the company does not designate no
disturbance areas.
o Not disclosed
China A
- Sub-Industry: Airlines
- Specific Guidelines: Must be scored.
- Specific Guidelines: Often Not Disclosed Commented [ACJ6]: @Lo, Riza Anne
Company designs infrastructure in a way that minimizes disturbances

(e.g., raised or underground pipelines; cross over bridges)
and natural habitat by designing infrastructures which minimizes
disturbance.
a) All operations
b) Core projects
c) Evidence of biodiversity protection activities, but scope is unclear
d) No evidence
• Keyword(s):
bridges, fish ladders, design for environment (DfE), industrial ecology
specific guidance
- Scoring:
o All operations – Select if the data point is applicable to all
operations.
Core projects – Select if the data point is only applicable to

o
core projects.
o Evidence of biodiversity protection activities, but scope is
unclear – Select if the company makes efforts to minimize
its impact but scope is not disclosed.
o No evidence
China A
- Specific Guidelines: Score Evidence of biodiversity protection
activities, but scope is unclear if Chinese issuers provide examples. Commented [ACJ7]: @Lo, Riza Anne
Company reintroduces diverse local flora and fauna in its rehabilitation

activities (as opposed to monocultures)
• Definition: This data point evaluates the company’s commitment to
reintroduce local species, flora, and fauna as part of its rehabilitation.
a) Yes
b) No
c) No evidence
• Keyword(s):
fauna, flora, animal, plant, introduce, introduction, release
- Scoring:
o Yes – Select this option if a company is committed to
reintroducing local flora and fauna.
o No
China A
- Specific Guidelines: Often Not Disclosed
Company monitors and addresses changes in local eco-systems (e.g.,

invasive species, drop in species population)
• Definition: This data point evaluates whether the company monitors and
addresses local ecosystem issues in their area of operations, such as
invasive species or a drop in species population.
a) Yes
b) No
c) Not disclosed
• Keyword(s):
invasive species, species population, species protection, species
conservation, ecosystem
specific guidance
- Scoring:
o Yes – Select if the company has programs to monitor
and/or address issues in local ecosystems.
o No
o Not disclosed – No information available.
China A
- Specific Guidelines: Often Not Disclosed
Company implements measures for pollution prevention and management

(e.g., spill containment, sediment minimization, toxin exposure
minimization)
• Definition: This data point evaluates whether a company implements
measures to prevent and control pollution in their areas of operation.
a) Yes
b) Minimum practices expected based on domestic industry norms
c) No
d) No evidence
• Keyword(s):
spill, sediment, toxin, pollution +prevention, pollution +management
specific guidance
- Scoring:
o Yes – Select this option if a company engages with local
communities in its area of operations.
norms
o No
o No evidence - No information available.
China A
- Sub-Industry: All Commented [ACJ8]: @Lo, Riza Anne

- Specific Scoring Guidelines:
More specific guidance or keywords for Chinese
o Yes – Sometimes scored for Chinese issuers issuers
o Not disclosed – Often scored for Chinese issuers
norms – Applies to all industries in CN market, default
scoring in case of no disclosure.
o Source:
Regulation for Eco-environmental Protection and
Reclamation for Mining

the Law of the People's Republic of China on Promoting

Clean Production
http://dj.cq.gov.cn/Html/20/zcfg/2016-7/131942.html
Company conducts biodiversity impact assessment prior to settling in new

areas
a) Yes
b) Minimum practices expected based on domestic industry norms
c) No
d) No evidence
• Keyword(s):
assess, impact, biodiversity, environmental, environmental impact
assessment, environmental impact variations, environmental impact
assessment
specific guidance
- This data point is different from the data point under “Programs &
Structures – Biodiversity and community impact assessment” as it is
a China A data point.
- Scoring:
Yes – Select this option if there is evidence that company

o
conducts biodiversity assessments in the area prior to
conducting operations.
norms
o No
China A
- Background: Generally, for all construction/mining projects, it’s
required by law to conduct environmental impact assessment
(including biodiversity) prior to setting in new areas
- Sub-Industry: All
- Specific Scoring Guidelines: Commented [ACJ9]: @Lo, Riza Anne
o Yes – Select this option if disclosure exists
o No – Selecting this option is not recommended. Reach out
to market experts for local language assistance if needed.
o Not Disclosed – Selecting this option is not recommended.
Reach out to market experts for local language assistance
if needed
norms – All industries in CN Market are applicable to give
credit if there is no evidence
▪ Source:
▪ For oil and gas
Administration of Offshore Oil Exploration and
Development
http://www.zhb.gov.cn/gzfw_13107/zcfg/fg/xzfg/201
605/t20160522_343314.shtml
▪ For mining and coal
Mineral Resources Law of the People's Republic of
China
040625_292.htm
reclamation needed for disturbed land, forest and
grassland
▪ For others
Law of the People's Republic of China on Evaluation of
Environmental Effects
http://www.zhb.gov.cn/gzfw_13107/zcfg/fl/201609/t2
0160927_364752.shtml
Industry Guidelines
- Industry:
JP IMI
- Sub-Industry: All
- Source:
Practices – Policies related to land rights and impact on local

communities
Scope of policies to minimize disturbances to traditional land use or ways
of life
disturbances to traditional land use or ways of life.
a) Policies cover all relevant operations
b) Policies cover selected operations
c) General commitment to minimize environmental impact of operations
d) No evidence
• Keyword(s):
traditional, land, indigenous people
- Scoring:
o Policies cover all relevant operations
o Policies cover selected operations
o General commitment to minimize environmental impact of
operations – Select if there is a general statement to
minimize disturbance to traditional land but scope or
applicability is not disclosed.
o No evidence
Stakeholders participation in developing biodiversity protection policies
and action plans
• Definition: This data point evaluates the stakeholders’ participation in
developing biodiversity protection policies and action plans.
a) Protection policies are aligned with or developed in partnership with

recognized international groups (Forest Sustainability Council, World
Wildlife Fund, Fauna and Flora International, Nature Conservancy,
Rainforest Alliance, International Union for Conservation of Nature)
b) Protection policies are aligned with or developed in partnership with
industry groups (e.g., International Council on Mining and Metals,
Sustainable Forestry Initiative)
c) Protection policies are aligned with local norms or developed in
partnership with local regulators universities or agencies
d) No evidence of membership or certification related to managing
biodiversity and land use risks
• Keyword(s):
biodiversity, protection, policies, stakeholders, consultation, engagement
specific guidance.
- Read the options carefully and choose the best option that describe the
company’s disclosure.
Local communities participation in developing biodiversity and community

rights protection policies and action plans
• Definition: This data point evaluates the local communities’ participation
in developing biodiversity and community rights protection policies and
action plans.
a) Community groups and councils are formed across all locations to
represent local interests
b) Community groups and councils are formed at majority of locations to
represent local interests
c) Local communities are consulted (e.g., surveys), but no formal
representation is established
d) No evidence of local community engagement in developing biodiversity
protection and land rights policies
• Keyword(s):
community, biodiversity, policy, council
Practices – Programs related to land rights and impact on local

communities
Scope of programs to protect indigenous people and land rights
• Definition: This data point evaluates the company scope of programs to
protect indigenous people and land rights.
a) Impact on local communities and traditional land use is assessed and
addressed across all key operations
b) Impact on local communities and traditional land use is assessed and
addressed at selected locations
c) General statement on community engagement and impact assessment
d) No evidence
• Keyword(s):
indigenous, land rights, precautionary
Extent of the company's local community engagement programs and

impact assessment
• Definition: This data point evaluates the extent of the company's local
community engagement programs and impact assessment.
a) Precautionary approached with ongoing impact monitoring process and
formal channels (grievance mechanisms) for local community
engagement
b) Reactive approach focused on addressing existing community concerns
c) General statements on supporting community engagement programs
d) No evidence
• Keyword(s):
community, grievance, engagement
- Note: that the disclosure provided must pertain to the company’s
engagement with local communities in their area of operations.
- Scoring:
o Precautionary approached with ongoing impact monitoring
process and formal channels (grievance mechanisms) for
local community engagement – Select if the company has
formal channels such as committees, task forces, and other

grievance mechanisms in place.
o Reactive approach focused on addressing existing
community concerns
o General statements on supporting community engagement
programs
Extent of external parties engagement in verifying biodiversity and

community rights protection
• Definition: This data point evaluates the extent of external parties’
engagement in verifying biodiversity and community rights protection.
a) All operations
b) Core projects
c) Evidence of external assurance, but scope is unclear
d) No evidence
• Keyword(s):
engagement, external +biodiversity, external +community
specific guidance
- Scoring:
o All operations
o Core projects
o Evidence of external assurance, but scope is unclear
o No evidence – No information available
Practices – Programs related to environmental impact

Scope of site-specific action plans to minimize adverse impact on
biodiversity and land
• Definition: This data point evaluates the scope of site-specific action plans
to minimize adverse impact on biodiversity and land.
a) All operations
b) Core projects
c) Evidence of biodiversity protection activities, but scope is unclear
e) No evidence of biodiversity protection activities
• Keyword(s):
impact +biodiversity
specific guidance.
- Scoring:
o All operations – Select this option if a company’s action
plan applies to all operations.
o Core projects – Select this option if a company’s action plan
applies to core operations only.
o Evidence of biodiversity protection activities, but scope is
unclear
norms
o No evidence of biodiversity protection activities – No
information available.
China A
Equipment & Services & Oil & Gas Storage & Transportation,
industry norms
- Source:
Regulations on Environmental Protection and Administration of
Offshore Oil Exploration and Development
http://www.zhb.gov.cn/gzfw_13107/zcfg/fg/xzfg/201605/t20160
522_343314.shtml
Regulation for Eco-environmental Protection and Reclamation for

Mining

Scope of programs to restore or rehabilitate disturbed areas

• Definition: This data point evaluates the scope of a company’s programs
to restore or rehabilitate areas disturbed by its operations.
a) Restoration efforts only active at a few current operational sites
b) Concurrent restoration efforts occur at all relevant operational sites

c) General statements on restoration and rehabilitation activities
d) No evidence
e) Minimum practices expected based on domestic industry norms
• Keyword(s):
restoration, rehabilitation, disturbed
specific guidance.
- Scoring:
o Restoration efforts only active at a few current operational
sites – Select this option if a company’s community
engagements with local communities exists in majority of
their operations.
o Concurrent restoration efforts occur at all relevant
operational sites
o General statements on restoration and rehabilitation
activities
norms
China A
- Sub-Industry: Metals and Mining
- Specific Guidance: Mine closure plans CANNOT be considered for
this data point because it is already a requirement for mining
companies.
Equipment & Services & Oil & Gas Storage & Transportation
industry norms
- Source:
o For oil and gas
Administration of Offshore Oil Exploration and Development
http://www.zhb.gov.cn/gzfw_13107/zcfg/fg/xzfg/201605/
t20160522_343314.shtml
o For mining and coal
625_292.htm
- reclamation needed for disturbed land, forest, and
grassland
Chemical Safety
This issue evaluates the extent to which companies may face lost market access or
product reformulation costs due to the presence of chemicals of concern. Scores are
based on exposure to products known to contain substances of high concern,
exposure to evolving regulations; chemical phase-out plans, transparency, and
development of viable alternatives; and controversies.
Strategy
Scope of chemicals identified for regulation under the management policy
• Definition: This data point refers to the scope of the chemicals the
company uses under the management policy
a) Comprehensive identification of all chemicals used
b) Comprehensive list of chemicals of concern based on an industry
standard or respected NGO
c) Small number of high profile chemicals identified
d) No chemicals identified
• Keyword(s):
SVHC, substance of very high concern, substance, chemical, reformulation,
reformulate, phase-out, MSDS. safety data sheet, EU REACH, Frank R.
Lautenberg Chemical Safety Act, Japan Chemical Substances Control Law
(CSCL), PRTR law, Pollutant Release and Transfer Register, Korea REACH,
China REACH, Turk REACH, Taiwan Toxic Chemical Substance Control Act
(TCSCA), Pollutant Release and Transfer Register, MRSL, Manufacturing
Restricted Substances List (MRSL), Restricted Substances List (RSL),
OEKO-TEX, bluesign, Chemsec, ZDHC, SAC, AFIRM, Leather Working Group,
EU RoHS, USA Frank R. Lautenberg Chemical Safety for the 21st Century
Act, China-RoHS, paraben, SIIN chemicals, restricted substances, BFR,
PVC, PFOA, BPA, Parabens, Phosphate, “有害物质”，“化学品”,“卤素”，“绿
色产品”
- Score if the company uses chemicals and there is information on which
chemicals were identified/used
- Look into SIIN list for other chemicals that are considered
o Utilized by Chemicals industry and Household and Personal
Products industry
o Create username and password
o https://sinlist.chemsec.org/
- Look into RoHS website for complete list
o 2022 RoHS Compliance Guide: Regulations, 10 Substances,
Exemptions (rohsguide.com)
- Look for the company’s disclosure on how it identifies and tracks
chemicals. It is difficult for products manufacturers to track chemicals
in their products as they purchase ready-made formulations from
upstream chemicals suppliers. Full lists don’t need to be publicly
disclosed but look for evidence the company is doing this
- Scoring:
o Comprehensive list of all chemicals used – Company
identifies all regulated chemicals (SVHCs, controversial
chemicals, SIN List), has its own assessment framework, or
has Materials Safety Data Sheets (MSDS) for all products;
Check to see if the company has a global chemical safety
management system (i.e. global database of substance
contents and toxins). If yes, then use this score; otherwise,
choose the NGO scoring
o Comprehensive list of chemicals of concern based on an
industry standard or respected NGO – Company is focused
on regulatory compliance in identifying chemicals, seems to
be extensive; Company identifies regulated chemicals
based on an industry standard (e.g., Responsible Care
Initiative)
o Small number of high profile chemicals identified –
Company seems focused on a few chemicals, e.g. parabens
& phthalates; Company addresses certain SVHCs/
Authorization List chemicals, has MSDS for some products,
or has a significant presence in the EU (compliance with
REACH regulations); This is also the score if the company
disclosed only RoHS restricted substances (see website
link in General Procedure)
o No chemicals identified – no disclosure
Industry Guidelines
- Industry: Textile, Apparel, and Luxury Goods
o Common standards and initiatives
• ZDHC, SAC, AFIRM, Leather Working Group
- Industry: EICC and Retailers

o Look for disclosure of MSDS from suppliers; can also
consider the database of companies if they have
- Industry: Household & Personal Products
o Sometimes MSDS are already available in the website
o We look for parabens in Cosmetics companies
o Chemical Safety Regulations for Household Durables
• EU RoHS, USA Frank R. Lautenberg Chemical
Safety for the 21st Century Act, China-RoHS
- Industry: Chemicals industries
JP IMI
- Industry: All
- Default Scoring: Small number of high-profile chemicals identified
- Source:
https://www.meti.go.jp/policy/chemical_management/law/prtr/2.html
- Sub-Industry: Electronic Equipment & Instruments; Electronic
Components; Electronic Manufacturing Services; Consumer
Electronics; Technology Distributors; Tobacco (E-Cigarettes only);
Persona Products
o Small Number of high-profile chemicals identified – if the
scope in not disclosed, then evidence of a formal policy +
identification of one or a few specific chemicals in the
policy/website/CSR
Scope of chemical phase-out plan

• Definition: This data point refers to the scope of their chemical phase-out
plan
a) Company has already phased out all chemicals of concern
b) Company has plans to phase-out all chemicals of concern
c) Company is targeting specific products and/or high priority chemicals
for reformulation
d) No evidence of plan for phasing out chemicals of concern
• Keyword(s):
reformulate, phase-out, phase out, MRSL, Manufacturing Restricted
Substances List, RSL, Restricted Substances List
- Most companies don’t disclose a systematic plan but may single out a
few high-profile chemicals. We define ‘chemicals of concern’ broadly
and somewhat flexibly – it could mean all chemicals on the SIN list, or
other relevant lists.
- We are trying to identify companies that are using regulatory pressure
as an innovation opportunity; phase-out will move from being an
innovation to a compliance issue (e.g., phasing parabens out of
cosmetics and finding alternative preservatives is expensive).
- Scoring
o Company has already phased out all chemicals of concern
– Company has phased out all substance of very high
concern (SVHC) or does not use any
o Company has plans to phase-out all chemicals of concern
– Company states that it is seeking alternatives to
substance of very high concern (SVHC) or ECHA’s
Authorization List chemicals
o Company is targeting specific products and/or high priority
chemicals for reformulation – Company only addresses
certain SVHCs or ECHA’s Authorization List chemicals
(example: phase out of parabens from cosmetics)
o No evidence of plan for phasing out chemicals of concern
– no disclosure found
Industry Guidelines
- Sub-Industry: Electronic Equipment, Instruments & Components
- Specific Guidelines: Most companies score No evidence or Company is
targeting specific products and/or high priority chemicals for
reformulation. Hardly any companies score Company has already
phased out all chemicals of concern
China A
- Sub-Industry: Electronic Equipment & Instruments; Electronic Commented [ACJ11]: @Lo, Riza Anne
Components; Electronic Manufacturing Services; Consumer
Electronics; Technology Distributors; Tobacco (E-Cigarettes only);
Persona Products
o Company is targeting specific products and/or high
priority chemicals for reformulation – mention one or a
few specific chemicals of concern in the context of
phasing-out plan commitment
Scope of chemical policy as it applies to proprietary and non-proprietary

products
• Definition: This data point refers to the scope of their chemical policy in
relation to their proprietary and non-proprietary products
a) Chemical standards apply equally to proprietary & non-proprietary
products
b) Different standards apply to proprietary & non-proprietary products
c) Chemical standards apply to proprietary products only
• Keyword(s):
reformulate, phase-out, phase out, proprietary, non-proprietary, MRSL,
Manufacturing Restricted Substances List, RSL, Restricted Substances List
- Score if the company has a chemical policy and it can be identified if
the scope is on the proprietary (company-owned) or if it extends to non-
proprietary products (not company-owned)
- Leave at No Value unless the company is involved in chemicals
production and distinguishes between proprietary/non-proprietary
- Scoring
o Chemical standards apply equally to proprietary & non-
proprietary products – scope of chemical standards
applies equally to both products that are company-owned
and not company-owned
o Different standards apply to proprietary & non-proprietary
products – scope of chemical standards applies to both
products that are company-owned and not company-
owned, but each have different standards
o Chemical standards apply to proprietary products only –
scope of chemical standards only applies to company-
owned products
Industry Guidelines
- Industry / Sub-Industry: Chemicals Industry, Electronic Equipment,
Instruments & Components, Retail – Consumer Discretionary
- Default Scoring: leave at No Value
- Sub-Industry: Household & Personal Products

- Scoring: leave at No Value unless the company is involved in chemicals
production and distinguishes between proprietary/non-proprietary.
China A
- Case # 1: If the China Issuer is part of EICC Commented [ACJ12]: @Lo, Riza Anne
o Specific Scoring Guidance: Leave at No Value. If Published
data was scored then change to “No Value”. If the industry
guidance were applicable.
- Case # 2: If China Issuers are in lack of further disclosure, then
o Specific Scoring Guidance: Chemical’s standards apply to
proprietary products only
Programs & Initiatives

Formal process to apply environmental / health standards in new product
design
• Definition: This data point refers to the application of environmental/health
standards in their new products and new product design
a) No evidence of commitment to measure the environmental/health
profile of new products
b) Company commits to future integration of environmental/health
standards in product design and/or plans to measure the
environmental/health profile of new products
c) Company measures environmental/health profile of new products as
part of product design (e.g. life-cycle assessments)
d) Company applies well-defined standards (e.g. Principles of Green
Chemistry, Cradle to Cradle certification, Organic certification)
• Keyword(s):
SVHC, substance of very high concern, life cycle, life cycle language, Green
Chemistry, product design, Organic certification, Cradle to Cradle
certification, MRSL, Manufacturing Restricted Substances List, RSL,
Restricted Substances List, Responsible Care, life cycle, lifecycle,
environmental footprint, sustainable material, green product, green
chemistry, design for environment, DfE, product stewardship, product
impact
- Green Chemistry – the Twelve Green Chemistry Principles, EPA – a
completely voluntary list of principles applied when formulating a new
substance. Could be designed for energy efficiency, etc. Principles help
companies to protect their innovation from future regulation. If
companies don’t measure the env/health profile, then they have no idea
if it has any kind of risk.
- Household Durable (HD) and Household & Personal Products (HPP)

companies
o Life cycle assessments are common; look for ‘life cycle’
language, measurement systems
o Principles of Green Chemistry are rarely found
- Responsible Care
o Chemical industries consider this (second highest score)
o Only score highest score if there are clear statements and
disclosures
- Scoring:
o No evidence of commitment to measure the
environmental/health profile of new products – no
evidence found
o Company commits to future integration of
environmental/health standards in product design and/or
plans to measure the environmental/health profile of new
products – company has commitments to measure
safety/environmental profile of their products and product
design; For Textiles, Apparel, and Luxury Goods: This
includes inspection of hazardous substances in compliance
with regulations and standards (e.g. Korea Certification,
Korea Apparel Testing); inspection of raw materials and
finished products
o Company measures environmental/health profile of new
products as part of product design (e.g., life-cycle
assessments) – Company conducts lifecycle assessments
(LCAs)
o Company applies well-defined standards (e.g., Principles
of Green Chemistry, Cradle to Cradle certification, Organic
certification) – Green chemistry is formally integrated into
product design process; group-wide initiatives to reduce
toxicity in process
Industry Guidelines
- Industry / Sub-Industry: Household & Personal Products
China A
- Scoring Guidance: Commented [ACJ13]: @Lo, Riza Anne
o Company measures environmental/health profile of new
products as part of product design – if the company
measures the environmental / health profile of its products

or routinely conducts life cycle assessments
Disclosure of substances registration and use

• Definition: This data point refers to the disclosure of the company
regarding their registration and/or use on their substances
a) Discloses all regulatory registrations and use
b) Only discloses high concern substances and use
c) Discloses all regulatory registrations
d) Only discloses substances identified as high concern
e) Not disclosed
• Keyword(s):
reformulate, phase-out, MSDS. safety data sheet, EU REACH, Frank R.
Lautenberg Chemical Safety Act, Japan Chemical Substances Control Law
(CSCL), PRTR law, Pollutant Release and Transfer Register, Pollutant
Release and Transfer Register, Korea REACH, China REACH, Turk REACH,
Taiwan Toxic Chemical Substance Control Act (TCSCA) , MRSL,
Manufacturing Restricted Substances List, RSL, Restricted Substances
List, paraben, SIIN chemicals [see general procedure below]
- Under regimes like ROHS, companies must register and disclose their
chemical substance use with a central regulator. Some companies
publish a list of chemical substances in their products and components
of the products and make such information available on their website.
Note the distinction between registration and use, and just registration.
- Very few Household & Personal Products companies disclose all
regulatory registrations and use of all their chemicals/substances in
their website
- We look for parabens in Cosmetics companies
- Look into SIIN list for other chemicals that are considered
o Utilized by Chemicals industry and Household and Personal
Products industry
o Create username and password
o https://sinlist.chemsec.org/
- Scoring:
o Discloses all regulatory registrations and use – company
discloses company's registrations with regulatory
requirements (example: EU REACH – European Countries,
Frank R. Lautenberg Chemical Safety Act – USA, Japan

Chemical Substances Control Law (CSCL) and PRTR law -
Japan, Korea REACH – South Korea, China REACH – China
(Mainland), Turk REACH - Turkey, Taiwan Toxic Chemical
Substance Control Act (TCSCA) - Taiwan) as well as the use
of ALL their substances; Best practice for using this score:
not only does the company disclose substances registered
by the company itself, but also registered substances that
the company uses i.e. substances registered by its
suppliers
o Only discloses high concern substances and use –
company discloses the high concern substance they use as
well as the use of these substances in their operation;
please note that we should not rely purely on MSDS for this
information
o Discloses all regulatory registrations – company discloses
company's registrations with regulatory requirements only
o Only discloses substances identified as high concern –
company discloses the use of substance of very high
concern (SVHC) OR company discloses the use of SVHC
and regulatory registrations BUT no mention of the use of
substances
o Not disclosed – no disclosure
Industry Guidelines
o Very few Household & Personal Products companies
disclose all the information needed for the highest score
on their website
EU Domiciles (excluding UK due to Brexit)

- Use “Discloses all regulatory registrations” for EU REACH market
default
China A
- Sub-Industry: Consumer Electronics, Household Appliances, Commented [ACJ14]: @Lo, Riza Anne
Communications Equipment, Technology Hardware, Storage &
Is the Minimum scoring will be removed as a default
Peripherals, Electronic Equipment & Instruments, Electronic scoring?
Components, Electronic Manufacturing Services, Technology
Distributors
- Default Scoring: Only discloses substances identified as high concern

- Source: Notice on strengthening environmental management of waste
electrical and electronic equipment (关于加强废弃电子电气设备环境管
理的公告 ):
http://www.mee.gov.cn/gkml/zj/wj/200910/t20091022_172222.htm
The waste electrical and electronic products Recovery
Management Ordinance (废弃电器电子产品回收处理管理条例):
China A
- Assess if the issuer discloses chemicals of concern from substances Commented [ACJ15]: @Lo, Riza Anne
perspective or product perspective.
o If the issuer discloses a few hazardous chemicals used in
the operation/production process, can choose option ‘Only
discloses high concern substances and use’
o If the issuer discloses hazardous chemicals that they
manage (not indicating that these are used in which
products), choose option ‘Only discloses substances
identified as high concern’.
Components; Electronic Manufacturing Services; Consumer Electronics;
Technology Distributors; Tobacco (E-Cigarettes only); Personal Products
o Discloses all regulatory registrations and use
• In case of no evidence, yet the issuer has operations
or has a significant portion of revenues (60%)
generated from EU
o Only discloses high concern substances and use
o Discloses all regulatory registrations
• Personal Product and E-cigarettes
Components; Electronic Manufacturing Services; Consumer Electronics;
Technology Distributors; Tobacco (E-Cigarettes only); Personal Products
- Default Scoring: Only discloses substances identified as high concern
Programs & Initiatives – Chemical Producers

Extent of substances or products hazard assessments
• Definition: This data point refers to the company assessment (e.g phasing
out, assessing hazards, etc.) of their substances and/or products
a) Conducts hazard assessments and commits to targets
b) Conducts hazard assessments for new substances
c) No evidence
• Keyword(s):
reformulate, phase-out, phase out, assessment, hazard, MRSL,
- Scoring:
o Conducts hazard assessments and commits to targets –
Targets regarding hazardous substances, phase-out
timelines, assessments of existing products, proprietary
hazard index; the company explicitly says that it conducted
or has time-bound plans to conduct hazard assessment of
substances in ALL of its products, not only new products
but also existing products on the market
o Conducts hazard assessments for new substances –
Default for companies in developed markets; the company
conducts hazard assessment for new substances and will
give the score of b.
o No evidence – no disclosure
Industry Guidelines
- Sectors: All sectors except Chemical Industries
- Industry: Retail – Consumer Discretionary

- Markets: Developed markets

- Default Scoring: Conducts hazard assessments for new
substances score if no evidence is found
o If the CN company’s products can be found under China -
IECSC through searching on the link, https://apciss.cirs-
group.com/?lang=en
o Give credit “Conducts hazard assessments for new
substances”
o Note: As the New Measures for the Environmental

Management Registration of New Chemical Substances
requirements launched in 2021, the chemicals registration
and filing process will be more comprehensive than before
including detailed analysis of hazardous impact on the
environment and healthy, also the analysis is required to be
verified by risk assessment experts committee from
Ministry of Ecology and Environment of China.
Demonstrated track record of introducing viable alternatives to high

concern substances
• Definition: This data point refers to the company's initiatives using or
developing alternative substances for high concern substances that the
company uses in their product formulations
a) Leading producer of alternative substances
b) Developing alternatives to high concern substances
c) No evidence
• Keyword(s):
SVHC, substance of very high concern, substance, chemical, alternative,
MRSL, Manufacturing Restricted Substances List, RSL, Restricted
Substances List
- Scoring:
o Leading producer of alternative substances – Significant
production of alternatives; the company explicitly mentions
that it is a leading producer of alternatives and mentions
what alternatives/specific substances they have used to
replace chemicals of concern
o Developing alternatives to high concern substances –
Alternatives to SVHCs, non-phthalate plastics, phthalate
alternatives, VOC-free, etc.; the company mentions that it is
developing alternatives and mentions what
alternatives/specific substances will be used to replace
chemicals of concern
Industry Guidelines
- Sectors: All sectors except Chemical Industries
JP IMI
- Sub-Industry: Specialty Chemicals; Diversified Chemicals;
Commodity Chemicals
- Default Scoring: Developing alternatives to high concern
substances
- Source: https://www.env.go.jp/hourei/12/000010.html
o This data point evaluates whether the issuer is developing
or has developed the alternatives to SVHC (substances of
very high concern, as in EU REACH).
o If the issuers are a market lead in this field of producing
alternatives to SVHC, give the highest credit Leading
producer of alternative substances.
o If it states there’re some level of involvement (e.g.,
production, research), give credit of Developing alternatives
to high concern substances.
Programs & Initiatives – Product Manufacturers

Demonstrated track record of phasing out and/or reformulating products
with chemicals of concern
• Definition: This data point refers to the extent of the company's efforts in
phasing out and/or reformulating products with chemicals of concern
a) No evidence
b) As required by law
c) Proactively (ahead of regulations or exceeds regulations)
• Keyword(s):
reformulate, phase-out, phase out, MSDS, safety data sheet, EU REACH,
Frank R. Lautenberg Chemical Safety Act, Japan Chemical Substances
Control Law (CSCL), PRTR law, Pollutant Release and Transfer Register,
Korea REACH, China REACH, Turk REACH, Taiwan Toxic Chemical
Substance Control Act (TCSCA), phthalate, non-phthalate, MRSL,
Manufacturing Restricted Substances List, RSL, Restricted Substances
List,
restricted substances, “消除” (eliminate, phase-out)，“禁用”(ban, phase-
out)，“减少”(reduce), chemicals （化学品)
- Check if the company is phasing out substances of concern or

canceled a product due to health concerns
- Scoring:
o As required by law – company phases out/reformulates
products with chemicals of concern as required by the
regulations in the country where they operate. Complying to
RoHS, REACH; majority in the industry
o Proactively (ahead of regulations or exceeds regulations)
– company phases out/reformulates products with
chemicals of concern before regulations were created in the
country where their operations operate or goes beyond the
expectations of the regulations of the country where they
operate
Industry Guideline
- Industry / Sub-Industry: Technology Distributors, Chemicals Commented [LRA18]: Pending query with Content
Industry Team. Below query is available in Adhoc Teams
Channel.
- Sub-Industry: Electronic Equipment, Instruments & Components For Technology Distributors, should this datapoint be
- Specific Guidelines: Most companies here have a scoring of No 'No value'?
evidence or As required by law
JP IMI
- Sub-Industry: All, Except for Technology Distributors, Specialty
Chemicals; Diversified Chemicals; Commodity Chemicals
- Default Scoring: As required by law
- Source: https://www.env.go.jp/hourei/12/000010.html
China A
- Specific Scoring Guidance Commented [ACJ19]: @Lo, Riza Anne
o Don’t choose ‘No Value’
Initiatives to improve consumer awareness on product chemical content

• Definition: This data point refers to the efforts of the company to educate,
inform, and address concerns of the consumers regarding the chemical
content of their products
a) Extensive information explaining chemical content to consumers (e.g.
website, app)
b) Channel for customer inquiries regarding chemical content (e.g. hotline,
webform)
c) No evidence
• Keyword(s):
SVHC, substance of very high concern, substance, chemical, MRSL,
- For Household & Personal Products - Look on consumer-facing part of
company website; also look for mobile scanning apps or query
channels. Not many companies do this.
- Scoring:
o Extensive information explaining chemical content to
consumers (e.g., website, app) – company has a section on
their company website, developed an app, etc. that
educates the consumers on the chemicals used in their
products
o Channel for customer inquiries regarding chemical content
(e.g., hotline, webform) – company has established a
section on their company website or a hotline that
addresses customer concerns regarding chemicals used in
their products
o No evidence – no disclosure found
Industry Guideline
- Industry / Sub-Industry: Electronic Equipment, Instruments &
Components Chemicals Industry, Electronics Components and
Electronic Manufacturing Services sub-industry
China A
- Specific Scoring Guidance: Commented [ACJ20]: @Lo, Riza Anne
o For EEIC, choose ‘No Value’ per industry scoring guidance
o How to assess for non-EEIC companies?
• Choose option according to evidence/disclosures.
• A Few Chinese issuers have hotline, website
designated to raising consumer awareness on
product chemical content.
Level of disclosure around product formulation

• Definition: This data point refers to the level of disclosure on their product
formulation
a) Not disclosed
b) Presence or absence of particular chemicals only
c) Full formulation for selected products only

d) Full formulation for a substantial number of products
• Keyword(s):
SVHC, substance of very high concern, substance, chemical, MSDS, safety
data sheet, formulation, MRSL, Manufacturing Restricted Substances List,
RSL, Restricted Substances List
- This indicator is consumer-facing, so try to find out about their
approach to labelling, or info may be available online if it is disclosed.
Aim is to determine whether info is available to consumers.
- Scoring
o Not disclosed – no disclosure
o Presence or absence of particular chemicals only –
Company is undertaking initiatives related to certain high-
profile chemicals. Example: Lead-free, RoHS-compliant
(since chemical within ppm range)
o Full formulation for selected products only – score if this is
available for one or two product lines
o Full formulation for a substantial number of products –
threshold is around 30% or more of product lines with
disclosed formulation
Industry Guideline
- Industry / Sub-Industry: Electronic Equipment, Instruments &
Components, Technology Distributors, and Chemicals Industry
China A
- Sub-Industry: Electrical and Electronic Products Commented [ACJ21]: @Lo, Riza Anne
- Scoring Guidance:
Confirm the sub industry
o if the Hazardous Substance Table is evidenced, choose
option ‘Presence or absence of particular chemicals only’
- Specific Guidance:
o check the companies’ products at
https://chinarohs.miit.gov.cn/#/declaration
• Producer ( 生产者 ): use this to search for the
company name then classify the Declaration Type (声
明类型)
▪ Presence of absence of particular chemicals
– if the company’s product report as “自我
声明”
• Full formulation for selected products only – if the

company’s product report as “国推自愿性认证”
- Sub-Industry: Personal products
o The product formulation is typically business confidential,
and companies are least likely to disclose that to public.
However, all the new cosmetics (including fragrances)
products need to be registered at National Medical Products
Administration ( 国家药品监督管理局数据查询
(nmpa.gov.cn)).
• In order to get approval of registration, the
formulation/ingredients information must be
provided to NMPA. Thus, strongly suggest looking for
the formulation information on packaging or product
manuals for some of specific products.
Climate Change Vulnerability

This issue evaluates the extent to which insurance companies may face risks to
insured assets or individuals associated with the physical effects of climate
change. Scores are based on insured exposure to geographies vulnerable to
climate change effects, and integration of climate change risks into product
strategy and risk management processes.
Climate change risk covers a range of categories, including physical risk (such as
more frequent hurricanes), regulatory risk (such as carbon pricing), market risk
(shifts in demand), reputational risk, and supply chain risk (effects on suppliers).
As bearers of risk, insurers need to take account of any additional risks that
climate change poses to their policyholders, since these will also affect the
insurance company. Because insurance products are based on risk, the
emergence of new risks also presents opportunities to insurance companies as
they develop new products and expand into new markets. The failure to identify
and respond to emerging risks therefore represents both greater unmitigated risk
for the insurer, and an opportunity cost, since first movers will gain an advantage
as demand for insurance against emerging risk increases.
Types of Insurance Company

Common business segments of different insurance companies.
L&H P&C Multi-Line Reinsu
Type of Insurance Company Insurance and rance
Brokerages
Life Insurance (SIC Code: 6311) - Common
products are term life and group life policies.
Life and ✓ x ✓ ✓
Provide life, annuity products, or retirement savings.
Health
Insurance
Accident & Health Insurance (SIC Code: 6321)–
✓ x x x
Covers medical expenses
Property Insurance - Insuring physical items such
as houses, factories, buildings, vehicles, etc.
Property & Casualty Insurance - Covers legal liability of the
Casualty insured customers. Applicable to doctors, medical
Insurance facilities, or manufacturing companies (e.g., food)
Fire, Marine, and Casualty Insurance (SIC Code:
x ✓ ✓ ✓
6331)
Multi-Line Insurance - Both products covering life
and non-life insurance. Combination of L&H and ✓ ✓ ✓ ✓
Multi-Line P&C.
Insurance Insurance Agents, Brokers, and Service (SIC Code:
and 6411)– Acts as intermediaries between insurance
Brokerages companies and buyers. Do not underwrite insurance x x ✓ x
products and their revenues are from commissions
and fees.
Surety Insurance (SIC Code: 6351) - Offers
Others
financial protection to lenders against the possible
default from the borrower. Mortgage insurance and

Trade Finance Insurance business falls under this
category.
Auto/Motor Insurance (SIC Code: 6399)– Property
casualty insurers offering auto/car insurance
products.
Title Insurance (SIC Code: 6361)– Specialty
insurance companies offer services to get the clear
title of the real estate property that the buyer is
planning to purchase. Further, in case of legal battle
involving these properties, these specialty insurance
companies assist buyers to defend the title and if
necessary, bear the cost of legal expenses for
settling the case.
Sources to be Used:
• CSR and TCFD
o TCFD - climate related disclosures like climate model, research, etc.
are usually found in this disclosure.
Performance
Comment on the company's specialty insurance products related to
climate change mitigation and/or incentives that mitigate both the
company and the customer's exposure.
• Definition: Indicates company's specialty insurance products related to
climate change mitigation and/or incentives that mitigate both the
company and the customer's exposure
N/A - Long Text
• Keyword(s):
‘insurance products’, ‘solar’, ‘electric vehicles’, ‘windmills’
• General Procedure: (Only Content Team updates this data point.)
- Look for examples of insurance products that help mitigate
climate change. Examples:
o Insuring solar panels, windmill, or electric vehicles
- Give details of all relevant evidence, with references
- If no available information, leave it blank.
Underwriting performance relative to peers, based on the company’s loss

ratio and combined ratio
• Definition: Refers to underwriting performance relative to peers, based on
the company’s loss ratio and combined ratio
(a) Losses are lower and more stable than peers

(b) Loss experience resembles peers on average
(c) Losses are more variable than peers - history of elevated losses
(d) Insufficient information
• Keyword(s):
‘combined ratio’, ‘loss ratio’
- Only measured using 3-year average of combined ratio. Refer to the
combined ratio table
- If only 1-2 years data is available, still use the scoring procedure below.
- Scoring:
o Losses are lower and more stable than peers – Combined
ratio three-year average is <=95%
o Loss experience resembles peers on average – Combined
ratio three-year average is >95% but <100%
o Losses are more variable than peers - history of elevated
losses – Combined ratio three-year average is >= 100%
Combined Ratio
• Definition: Indicates company’s combined ratio for the fiscal year.
• Keyword(s):
‘Combined ratio’
- Always create a row even if no evidence found.
o For those published issuers that do not have rows, create 3
rows, and add the year. Provide internal notes that there is
no evidence found.
- Combined ratio measures the extent of which the company is paying
out claims/premiums. The lower the combined ratio, the better for the
company.
- Fill the data given in the current annual report, 10K, financial
supplements
- Use the combined ratio disclosed by the company. Do not compute it.
- Where companies disaggregate their disclosure for these ratios for
different types of insurance or different regions, use the Property line
ratios, instead of liability line ratios.
o For combined ratio, please make sure to assess only
property insurance. Sometimes P&C insurers have other
segment like cyber insurance/title/surety insurance. But we
only look at combined ratio of insurance products that can

be related to climate change/catastrophe.
Loss Ratio
• Definition: Indicates company’s loss ratio for the fiscal year.
• Keyword(s):
‘loss ratio’
- Always create a row even if no evidence found.
o For those published issuers that do not have rows, create 3
rows then add the 3 latest years. Provide internal notes that
there is no evidence found.
- Fill the data given in the current annual report, 10K, financial
supplements
- Use the loss ratio disclosed by the company. Do not compute it.
- When companies disaggregate their disclosure for the ratios of
different types of insurance, use the Property & Casualty ratio.
Description Field of Combined and Loss Ratio

- If it is a P&C company, only add the source.
- If the company has multiple segments (i.e., life and health and
property & casualty) add a note that the combined ration pertains
to this segment and add the source. This is because if companies
disaggregate their disclosure for the ratios of different types of
insurance, we consider the P&C Ratio
o Example: Combined Ratio of Property & Casualty. AR 2021
page 14
Practices
Climate change listed as a business risk factor
• Definition: Refers if the company listed climate change as a business risk
factor.
• Keyword(s):
'catastrophe', 'hurricane', 'typhoon', 'climate risks'
(a) Yes - in mainstream financial reporting
(b) Yes - in CSR or sustainability report
(c) Implied - but not stated directly

(d) No
- Search for ‘climate change’, ‘climate risk’, ‘catastrophe’, ‘weather’
- Check the ‘risk factors’ section of the AR.
- Scoring
o Yes - in mainstream financial reporting
• The company should mention that climate risk as
specific risk factor.
• the issue is clearly identified as a risk in annual
report, financial statement, financial performance
presentation materials other mainstream financial
reporting.
• Please check the ‘risk factors’ section of the annual
report. General mention of ‘natural disasters’ and
‘catastrophes’ and ‘bad weather’ is not sufficient and
should be scored as ‘Implied’. Even if the term
‘climate change’ is not used, if the company conveys
an awareness of climate change (e.g., ‘changing
weather patterns’) in the risk section, this can be
scored.
o Yes - in CSR or sustainability report
• The company should mention that climate risk as
specific risk factor.
• The issue is clearly identified as a risk in CSR or
sustainability report.
• Please check the ‘risk factors’ section. General
mention of ‘natural disasters’ and ‘catastrophes’ and
‘bad weather’ is not sufficient and should be scored
as ‘Implied’. Even if the term ‘climate change’ is not
used, if the company conveys an awareness of
climate change (e.g., ‘changing weather patterns’) in
the risk section, this can be scored.
o Implied - but not stated directly
• the issue is discussed but not explicitly stated as a
business risk
• General mention of ‘natural disasters’ and
‘catastrophes’ and ‘bad weather’.
Research related to climate change insurance risks

• Definition: Refers to company research related to climate change
insurance risks
(a) Yes - produces primary research
(b) Implied - through participation in an industry consortium
(c) No
• Keyword(s):
‘research’, ‘assessment’, ‘collaboration’, ‘white paper’
- The company is undertaking some research on climate change,
emerging risk related to climate change, or extreme weather.
- Only include primary research, white papers, or presentations.
- Check the AR/CSR and their websites.
- Do not consider secondary articles or research.
- Scoring:
o Yes - produces primary research -
• original research conducted in-house
• Published white papers, primary research,
presentations.
o Implied - through participation in an industry consortium -
partnership with university, NGO, government, industry body
etc. to conduct climate change research.
Use of statistical or mathematical models to model climate change effects

in actuarial assessments
• Definition: Refers if company uses statistical or mathematical models to
model climate change effects in actuarial assessments (e.g., -2-degree
scenario and scenario analysis)
(a) Yes - uses or creates CC models with evidence of integration into
actuarial assessment
(b) Implied - uses or creates CC models but no evidence of integration into
(c) No
(d) Not applicable
• Keyword(s):
‘statistical analysis', ‘climate modeling’, ‘scenario analysis’
- For this data point, we are looking for two points.
Evidence of climate modeling

o
If there is a model, check whether the company is using it in
o
their underwriting operations.
o Investment related climate modeling will not get credit here.
CCV is for physical risk modeling/ underwriting side of the
business
- Note that it is not enough that the company mentioned the
assessment. We should also check for the climate catastrophe model
in place and if financial risks are considered.
- Scoring
o Yes - uses or creates CC models with evidence of integration
into actuarial assessment-
• Use climate change model AND integration in
• Examples: Incorporating the model either in
▪ deciding the premium being charge to
customers
▪ underwriting those insurance products
▪ loss assessment – climate model indicates
that these businesses could see that there
will be 5-10% losses over the medium/long-
term.
o Implied - uses or creates CC models but no evidence of
integration into actuarial assessment – Use of climate change
model but no evidence of integration in actuarial process.
o No – No evidence
o Not applicable – Insurance brokers and/or special kinds of P&C
companies (e.g., Surety insurance and Title Insurance)
Exposure
Property and Casualty Lines as % of Total Premiums
• Definition: Indicates the percentage of the premium related to Property and
Casualty Lines.
• Keyword(s):
‘Property and Casualty’, ‘P&C’, ‘premium’
- Check the breakdown of premiums instead of the revenue breakdown.
- Use the gross written premium figure for the calculation for the P&C
and L&H premium.
- Enter zero if there’s no P&C Insurance.

Industry Guideline
- Surety insurance - Remove the P&C premium calculation, please
don’t include surety insurance premium into P&C premium in your
calculation
Reinsurance Lines as % of Total Premiums

• Definition: Indicates the percentage of reinsurance that company has
assumed from other company for P&C insurance.
• Keyword(s):
‘Property and Casualty’, ‘P&C’, ‘reinsurance’, ‘assumed’
- Reinsurance value that companies have assumed from other company
for P&C insurance
- Assumed vs Ceded
o Assumed: provided service by the insurer consenting to
take risk from another insurer. Additional risk that the
company is taking.
o Ceded: insurer is transferring the risk of their portfolio to
another company. Reinsurance that the company is paying
to the reinsurance company.
- Use the gross written premium figure as denominator for the
reinsurance line calculation
- Enter zero if there’s no reinsurance.
- Example: METLIFE, INC. 10K 2019
CCV Key Issue IHDR Key Issue

Property and Casualty Lines as (3,740+19)/(42,513+
% of Total Premiums 2020)=8.44%
Life and Health Lines as % of (23,938+14,835+1794+207)/(42,513+20

Total Premiums 2)= 91.56%
Reinsurance Lines as % of
19/(42,513+ 2020)= 0.04% (1,794+207)/(42,513+2020)=4.49%
Total Premiums
Common LM/HCD
Exposure – Total workforce composition
We cannot add rows to this table. We need to wait for the Exposure team to
add rows and update the Total Workforce column. Only update below data
points.
• Note: Total workforce reported in this table is usually the average number of
employees or full-time employees. Hence, if we compute for Salary per
employee (in USD) and Profit per employee (USD ‘000), we should check for
the total number of employees (including part-time, contractor, or temporary
workers).
Number of full-time or permanent employees
• Definition: Indicates the total number of full-time or permanent employees
N/A – Numeric Value
• Keyword(s):
- Do not update this field.
Number of part-time, contract, or temporary workers

• Definition: Indicates the total number of part-time, contract, or temporary
workers
• Keyword(s):
- Do not update this field.
Total Workforce
• Definition: Indicates the company’s total number of employees
• Keyword(s):
‘full-time’, ‘part-time’, ‘seasonal’, ‘temporary’, ‘fixed-term’, ‘contractual’
- Provide the total number of employees regardless of its type. Always
consider the group data.
- Types of employees: full-time, part-time, seasonal, temporary, fixed-
term, contractual, etc.
- In case there is more than one data about the employees, check the
following:
o Company name: Check the company name and the notes
as sometimes company discloses total employees of
parent company or other subsidiaries.
o Group vs standalone: Always consider the group data of the
company.
o Total vs average: Prioritize total number of employees
instead of average number of employees. In the absence of
total, use the average number of employees.
o Corporate Action: If there are any CA events (i.e., M&A, spin-
off, demerger, etc.), consider the total number of employees
after the CA event is fully implemented.
- Note: Given that we will be maintaining this data point, the total
workforce under this table should be used to compute the salary per
employee and profit per employee. Commented [LRA22]: Still under discussion. Do not
use.
Total number of employees in executive management (C-suite)

• Definition: Indicates the total number of employees in executive
management.
• Keyword(s):
‘executive’, ‘management’, ‘leadership’, ‘Chief’, ‘CEO’
- A team of individuals at the highest level of management of an
organization. Job Titles such as Chief Operating Officer (COO), Chief
Executive Officer (CEO), Chief Financial Officer (CFO), President, Vice
President are commonly used by top managers in organizations.
- The Executive Committee is normally headed by the CEO or Chairman.
They are not the Board of Directors, but some Board members may be
part of Executive leadership.
- If it is a team of 15 or less members and lead by CEO or Chairman,
consider them as Executive Team. If it is a team of more than 15
members, separate the C-suite officers and any heads of business
units as Executive Team and the rest in the team as Senior

Management.
- In case of a company with very large workforce like 40,000 - 80,000
employees than we can assume that it would be having many people
in its executive team. Use your understanding of the company’s
organizational structure/hierarchy pyramid in such cases.
- In case of group companies with multiple subsidiaries would be having
multiple CEO and executive members in team which might exceed the
15 number count stated earlier. Use your understanding of organization
structure in such cases
- Note that the Total number of employees in executive management (C-
suite) should not be greater than the Total number of employees in
senior management (managers and above).
•Guidelines for Specific Industry / Market

Japan
Japanese Executives
Not Counted as Executive or Senior Management
chairman of the board of directors, usually not an
会長 kaichou
executive officer unless otherwise specified
取締役 torishimariyaku company director
監査役 kansayaku auditor, not counted as executive
当社 tousha this company,
社外 shagai outside the company
Counted as Executive
社長 shachou company president, usually CEO
副社長 fukushachou company vice president
department head, usually counted as executive
部長 buchou management IF on the list of board members; otherwise,
counted as senior management
general manager, usually counted as executive
本部長 honbuchou management IF on the list of board members; otherwise,
executive officer, usually counted as executive
執行役員 shikkouyakuin management IF on the list of board members; otherwise,
Counted as Senior Management


Names
If name ends with 子 ko, count as female.
If name ends with 也 ya, 夫 o, 男 o, 郎 rou, or 介 suke, count as male
China
Chinese Executives
First: Search for this keyword “董事、监事和高级管理人员” (Directors, Supervisors and
Senior Management) to check the table for Executive and Senior Management

董事长
董事 Director or Board of Trustee
独立董事 Independent Director
委员会 / 黨委書記 Member of the Party Committee
董事會秘書、公司秘書 Secretary of the Chairman of the board
职工监事 Employee Supervisor
监事 Supervisor
总裁 /执行总裁 company president / CEO
副总裁 company vice president
常务副总裁 /执行副总裁 Executive Vice President
财务总监 CFO
常務副總經理 Deputy General Manager
资深副总经理 Senior Deputy General Manager
總經理 General Manager

This can’t be included however if the person has
执行董事 responsibilities or handling the company this can be
consider as the Executive Management.
協理 Associate or Assistant of Head Department
資深經理 Senior Manager

Gender (性别)
If 女, count as female.
If 男,count as male
Service Status (任职状态)
If the service status is 现任 (Incumbent or Official), this can be included on the count.
If the service status is 离任,this should be excluded. Note: check the End Date, if the person
served a whole year hence this can be still considered.
Some reports reported in Start and End Date

任期起始日期= term start date
任期终止日期 = term end date
Total number of employees in senior management (managers and above)

• Definition: Indicates the total number of employees in senior management.
• Keyword(s):
'management', 'senior management'
- A team of managers at senior positions who are responsible for
planning and directing the work of a group of individuals.
- When the company does not define executive team but states all under
heads like Management team, Officers, Supervisory team etc.
- If it is a team of 15 or less members and lead by CEO or Chairman,
consider them as Executive Team. If it is a team of more than 15
members, separate the C-suite officers and any heads of business
units as Executive Team and the rest in the team as Senior
Management.
- Additional Note for identifying senior management: If the company
identifies two tiers of top managers, e.g., an ‘executive committee’ or
‘senior leadership’ PLUS an additional larger set of people, put the first
group in “executive management” and the second ground in “senior
management”.
- Total number of employees in senior management (managers and

above) should be greater than Total number of employees in executive
management (C-suite).
•
Guidelines for Specific Industry / Market
Japan
Japanese Executives
会長 kaichou

Names
China
Chinese Executives

董事长
监事 Supervisor
财务总监 CFO

This can’t be included however if the person have a

Gender (性别)

Estimated percentage of workforce that is part-time, or temporary

• Definition: Indicates the percentage of part-time or temporary employees
in the company.
• Keyword(s):
'part-time’, ‘contractual’
- Provide the percentage of part-time or temporary employees in the
company. If percentage is not available and company provided the total
number of part-time employees, divide it to the total workforce.
- If the company discloses figures for both part-time and temporary
employees and the numbers are not aligned, please collect data for
temporary employees.
Exposure – Layoffs and M&A Events

- Add a row even if there is no evidence of layoffs and mergers and
acquisitions.
- This table should be aligned with Labor Management’s layoffs and
restructuring data points.
More than 10% of workforce or more than 1,000 employee are affected by layoffs
• Definition: Evidence of layoffs of more than 10% of workforce or more than
1,000 employees
(a) Yes
(b) No Evidence
(c) Not Disclosed
• Keyword(s):
‘employee dismissal’, ‘headcount reduction’, ‘lay-off’, ‘termination of

employees’, ‘job cut’, ‘workforce reduction’
layoffs (裁员)
- If the company has laid of more than 10% employees or 1,000
employees, mark this data point as Yes.
More than 10% of workforce or more than 1,000 employee are affected by
Mergers & Acquisitions (M&A) Commented [LRA23]: Company samples - 10% or
• Definition: Provides information if more than 10% of workforce or more more of assets – Content Team
than 1,000 employees are affected by Mergers & Acquisitions (M&A)
(a) Yes
(b) No Evidence
(c) Not Disclosed
• Keyword(s):
‘merger’, ‘mergers and acquisitions’
M&A (并购)
• Sources:
- Annual Reports, Financial Statement, CSR, Google Search
- If more than 10% of workforce or more than 1,000 employees are
affected by the mergers and acquisition, mark this data point as Yes.
- While the terms “Merger” “Acquisition” or “M&A” may not be explicitly
mentioned in company disclosures, there may be news regarding the
company acquiring/purchasing several small or medium sized firms
which may result in an impact of +/- 10% of workforce OR more than
1,000 employees. Aside from company’s disclosures, use Google to
further search on news/articles about M&A.
- Analysts should take note of any major swing in headcount or FTE
totals year on year, as this could indicate a M&A or company purchase
activity without keywords present in disclosures.
- If there’s no evidence found, do not mark this as ‘Not Disclosed’.
Industry Guideline
- Sector: Financials
o If more than 10% of workforce or more than 1,000
employees are affected by the mergers and acquisition,
mark this data point as Yes. The easiest way is to find info
on acquisitions in 10K/20F/annual reports (“Business

Combination” or “M&A activities”), and look at the biggest
ones. Make your judgment based on # of employees at the
acquired firm, relative size of the companies involved (it’s
usually not a big deal for a very big company to buy up a very
small firm) etc.
o Provide internal notes of reasoning and timing for this.
Practices - Operations
Material non-pay benefits
• Definition: Indicates the strength of material non-pay benefits offered, if
any.
(a) Broad range of non-statutory benefits
(b) Selected non-statutory benefits
(c) Statutory benefits only
(d) Minimum practices expected based on domestic industry norms
(e) No evidence
• Keyword(s):
'benefit', 'salary', remunerations', 'employee welfare', 'wages'
- NOTE (Temporary Guideline): To consider in Broad range of non-
statutory benefits, the company should have non-statutory benefits
beyond the mandated by law or benefits extended to
family/dependents of employees.
- The indicative list of major non-compensation benefits include pension
(defined benefit pension plan, substantial matching on defined
contribution plan e.g., 401k), retirement plans (Simplified Employee
Pension Individual Retirement Account (SEP IRA), etc.), housing
(employer-provided or employer-paid), group insurance (health, dental,
life etc.), disability income protection, tuition/certification
reimbursement.
- Use this to capture other non-financial compensation or benefits. Since
companies in this industry normally provide good financial
compensation and non-salary benefits, we only consider non-salary
perks with material value to employees, for example the ones listed
below with *. This type of benefits includes but not limited to:
o adoption assistance
o support for childcare and elder care
o flexible working arrangement
oremote work arrangement

ointernal transfer opportunities*
oeducation reimbursement (of material financial value, e.g., USD
2000 per employee per year) *
o unusually strong medical and health care benefits (covering
both employees and dependents, high financial value compared
to market norms) *
o unusual paid leave* (maternity/paternity leave that exceeds
statutory minimum leave, e.g., over four months in China, 12
weeks in the US, sabbaticals – not the usual type of holidays
and vacation)
- Note that the following are considered “substantial non-compensation
benefits” in key markets:
o USA: health, dental, and life insurance; 401k top-up (pensions
are increasingly rare)
o Canada: additional health and dental insurance, RRSP top-up
(pensions are increasingly rare)
o UK: professional & private health insurance, defined benefit
pension plan or generous/above legal minimum employer’s
pension contributions, paternity leave
o Europe: work-life balance arrangements (e.g., working from
home, flextime)
o Australia: health insurance (not common but possible), gym
and other club memberships
o South Africa: health insurance and pension contribution
o China:
▪ flexible working hours
▪ wfh option
▪ free breakfast, lunch, and dinner
▪ housing allowance
▪ additional medical/health-care insurance
▪ training course subsidies
▪ psycho-health hotline
▪
o Hong Kong:
▪ 16 weeks’ maternity leave
▪ 10 days’ paternity leave
▪ a group medical insurance plan that covers
▪ outpatient, inpatient, dental and childbirth items, as
▪ well as a family medical insurance plan that offers
the same coverage provided to employees
▪ psychological counselling services

▪ early off work on the eve of holidays
▪ rental reimbursement and
▪ education allowances,
▪ Occupational Retirement Scheme better than
statutory requirements
▪ life and accident insurance
▪ free health and dental check-ups
▪ preferential rates on mortgages and personal loans
▪ A retiree club holds regular activities to facilitate
contact and communication among retired
employees, who are also provided with medical
benefits
o Taiwan:
▪ Signed preferential childcare contracts with
kindergartens to assist colleagues in their children’s
childcare needs
▪ Signed short-term home care preferential contracts
with providers to assist colleagues in their family
care needs
▪ A total of 148 employees from various units were on
unpaid parental leave, and the return-to-work rate
was 75.68%; the number of employees who applied
for a childcare subsidy reached 1,125, while the
subsidies paid out totaled $xxx
▪ A full-time dedicated healthcare team has been set
up to take care of the health of employees. The
participation rate for health checkups was 85%
o Korea: Statutory benefits for permanent employees include
medical insurance, pension plan, employee insurance, and
casualty insurance. For contractors, this varies across different
types of contractors.
- Broad range identifiers for each industry to be provided by Content Team Commented [LRA24]: Pending query with Content
• Guidelines for Specific Industry / Market Team. Below query is available in Adhoc Teams
Channel.
China A
- Default Scoring: Statutory benefits only As per last comment, full list of broad range identifiers
- Source: Social Insurance Law of the People’s Republic of China: for each industry will be provided.
Each worker has endowment insurance and employment injury
insurance.
http://www.mohrss.gov.cn/SYrlzyhshbzb/zcfg/flfg/fl/201601/t201
60111_231408.html
o China: Regulator: 政策_中华人民共和国人力资源和社会保 Commented [LRA25]: @Atilano, Cristine Joyce, can
you confirm?
障部 (mohrss.gov.cn)
▪ “Five insurance and one fund” (China statutory):
• endowment insurance（养老保险）
• medical insurance（医疗保险）
• unemployment insurance（失业保险）
• work-related injury insurance（工伤保险）
• childbirth insurance（生育保险）
• housing accumulation funds（住房公积金）
▪ Public holidays and Paid leave
▪ Maternity leave: no less than 90 days
o Hong Kong : Regulator:
▪ Labour Department - Overview of Major Labour
Legislation
▪ Labour Department - A Concise Guide to the
Employment Ordinance
▪ Typical statutory benefits:
• Mandatory Provisional Funds - MPF (Hong
Kong statutory)
• Wage Protection
• Rest Days
• Holidays with Pay
• Paid Annual Leave
• Sickness Allowance
• Maternity Protection – 14 weeks leave
(continuous)
• Statutory Paternity Leave– 5 days leave
• Severance Payment
• Long Service Payment
• Employment Protection
• Termination of Employment Contract
• Protection Against Anti-Union Discrimination
- Broad range of non-statutory benefits

- Types of non-pay benefits that count:
o Housing benefits (rental reimbursement/allowance,
company mortgage loans; Note: mutual fund of housing is
mandatory in China),
o Transportation benefits (car purchasing/energy

reimbursement; shuttle bus),
o Group Insurance (commercial medical insurance, annuity),
o Adoption Assistance,
o Defined Benefit Pension Plan e.g., 401k/Annuity/Corporate
Pension (note: social security fund is mandatory in China)
o Communication cost reimbursement (i.e., monthly
allowance of mobile plan charge at a fixed/float base)
o Tuition Reimbursement (i.e., for employee and/or children
education)
o Disability Insurance (i.e., statutory in China, unless
additional insurance specified)
o Dental insurance
Workforce eligible for material non-pay benefits

• Definition: Indicates the scope of the company’s workforce covered for
non-compensation benefits
(a) Benefits cover all employees
(b) Benefits cover selected employees
(c) Scope not determinable
(e) No evidence
• Keyword(s):
'benefit', 'salary', remunerations', 'employee welfare', 'wages'
- Clear evidence in the company disclosure documents stating the
scope of the benefits. If the list of non-statutory benefits is provided
and the disclosures do not clearly state which employees can avail
these benefits, then the more conservative selection must be picked;
either “Scope not determinable” or “No evidence”.
- If the answer in Material non-pay benefits is Statutory benefits only,
then, Workforce eligible for material non-pay benefits should be 'No
evidence'
- Scoring:
o Benefits cover all employees – if full-time / permanent AND
part-time/ contractor/ temporary employees
o Benefits cover selected employees - if all permanent
employees excluding part-time and contractors are eligible for
non-statutory benefits
o Scope not determinable – if no indication of scope
No evidence – If no disclosure of substantial non-

o
compensation benefits
• Guidelines for Specific Industry / Market Commented [LRA26]: To confirm. Pending with
China A Content Team.
For China A default scoring:
- Default Scoring: Benefits cover selected employees
- Source: Social Insurance Law of the People’s Republic of China: Each If Material non-pay benefits is scored as Statutory
worker has endowment insurance and employment injury insurance. benefits only, should Workforce eligible for material
http://www.mohrss.gov.cn/SYrlzyhshbzb/zcfg/flfg/fl/201601/t201601 non-pay benefits be Benefits cover selected
employees?
11_231408.html
Employee stock ownership plan (ESOP) or employee stock purchase plan

(ESPP) Commented [LRA27]: More information on ESOP and
• Definition: Refers to who are eligible to participate in the company's ESOP ESPP Financials - Content Team
or ESPP.
(a) Sector-leading number of employees eligible for ESOP and/or ESPP
(b) Only select number of employees eligible for ESOP and/or ESPP
(c) ESOP or ESPP but scope of coverage is unknown
(d) No evidence of ESOP or ESPP
• Keyword(s):
'ESOP', 'ESPP', 'employee stock', 'stock option', 'share option', 'profit sharing
scheme', 'stock-based compensation', 'share based program'
- Clear evidence in the company disclosure documents stating the ESOP
or ESPP scope. If the disclosures do not clearly state which employees
can avail the ESOP or ESPP, then the more conservative selection must
be picked; “ESOP or ESPP but scope of coverage is unknown”.
- This must be for non-officer employees. Do not consider if the ESOP is
only for executives, board members, management, or officers.
- If has Equities is False in Company tab, Employee stock ownership plan
(ESOP) or employee stock purchase plan (ESPP) should be No Value.
- Scoring:
o Sector-leading number of employees eligible for ESOP
and/or ESPP - The company states that it offers an ESOP
and/or ESPP to its entire workforce or describes the range
of employees that are eligible, and this represents a large
percentage of the workforce compared to industry peers.
The company confirms that the plan applies to a substantial
portion of employees (not just high-ranking or performing
employees). Commented [LRA28]: Percentage of the workforce?
o Only select number of employees eligible for ESOP and/or

ESPP - There is evidence that the company offers an ESOP
and/or ESPP, but the company states that only certain
employees are eligible.
o ESOP or ESPP but scope of coverage is unknown - There is
evidence that the company offers an ESOP and/or ESPP, but
the scope of eligibility is unknown.
o No evidence of ESOP or ESPP - There is no evidence of an
ESOP or ESPP.
Industry Guideline
- Market: US, DM Europe, and Australia
- Scoring: ESOP or ESPP but scope of coverage is unknown
- IVA Industry: Supranationals & Development Banks

o Should be No Value as this is a fixed income issuer.
- Sector: Real Estate

o Stock purchase plan should enable employees to purchase
company’s stocks at a discount (usually at 85% of the
market price)". Reserve 'Sector-leading' score for
companies that offer workforce-wide coverage AND
discounts.
China A
- Check Annual Reports (Mandatory disclosure) OR CSR
- According to the Management Measures for Equity Incentive of Listed
Companies ( 上市公司股权激励管理办法 ) Article 65 and the
Memorandum of Information Disclosure of Listed Companies (上市公
司信息披露业务备忘录), ALL listed companies in mainland China shall
disclose the following information when launching ESOP/ESPP:
o scope of the incentives, including the names of directors,
supervisors, senior managers, and others who participate in
the plans,
o total amount of equity granted, exercised, and lapsed during
the reporting period.
- Therefore, even we could not find detailed disclosures of the scope of
ESOP/ESPP in annual reports, if it is evident that the company has
ESOP/ESPP, we give default credit “only select number of employees

eligible for ESOP and/or ESPP” for ALL China issuers Commented [LRA29]: @Atilano, Cristine Joyce
Practices - Employees
Engagement surveys to monitor employee satisfaction
• Definition: Indicates the frequency of the company's employee
engagement results are being conducted
(a) Surveys conducted annually
(b) Surveys conducted sporadically
(c) General statements about engagement initiatives
(e) No evidence
• Keyword(s):
'survey', 'satisfaction', 'feedback', 'engagement
- Most often this means employee surveys covering job satisfaction
issues. But take note if the company mentions employee engagement
or satisfaction.
- No credit given for surveys only focus on trainings or some specific
metrics
- Scoring below also applies for companies that who have outsourced
the survey to third parties.
- Scoring:
o Surveys conducted annually
▪ There must be at least two consecutive years of an
“Annual Survey” for a company to be given credit for
“Surveys Conducted Annually.”
• Case 1: If a company has a survey
monitoring employee engagement in 2020,
even if it is labeled as “annual” in their
disclosures, they must also have it in 2021,
before “annual” credit can be provided. For
first year of survey rollout, “sporadic” option
should be selected.
• Case 2: If the company only disclose general
statement about their survey (e.g., We
conduct Employees Pulse Survey) and
evidence was disclosed for two consecutive
years, then, this should only be considered as

General statements about engagement
initiatives.
o Surveys conducted sporadically
▪ Surveys conducted biennial or once every two years,
surveys are done once every three years or on the
ad-hoc basis only.
▪ For first year of survey rollout, “sporadic” option
should be selected.
• Case 1: If the company was scored as
sporadic due to the first survey roll out in
2021 but there’s no evidence found in 2022,
downgrade the score to ‘general statement’,
till the next assessment year which may offer
more clarity.
- Different Scenarios:
o Scenario I
▪ Last year assessed as: Surveys conducted annually
▪ Is information available this year? The company
conducts survey every two years.
▪ Action this year: Change to ‘Surveys conducted
sporadically' since we have evidence that survey is not
annual
o Scenario II
▪ Last year assessed as: Surveys conducted annually
▪ Is information available this year? No information found
this year
▪ Action this year: Retain the data points and don’t mark
‘No evidence’
Please select frequency with which the company conducts employee

engagement surveys. (Child data point)
• Definition: Indicates the frequency with which the company conducts
employee engagement surveys.
(a) Biennial or once every two years
(b) Annual or once a year
(c) Semi-annual
(d) Quarterly
(e) Evidence of employee engagement surveys, but frequency is not clear
(f) No evidence
• Keyword(s):
'survey', 'satisfaction', 'feedback'
- Select “Surveys conducted annually” if child data point is scored as at
least “Annual or once a year”.
- Select “Surveys conducted sporadically” if child data point is scored as
“Biennial or once every two years” or surveys are done once every three
years or on the ad-hoc basis only.
- Select “General statements about engagement initiatives” if child data
point is scored as “Evidence of employee engagement surveys, but
frequency is not clear”.
- Select “No evidence” child data point is scored as “No evidence”
Employee engagement survey results

• Definition: Indicates the company's disclosure of employee engagement
survey results
(a) Company tracks performance over time and takes action in response
(b) Company discloses engagement results
(c) Minimum practices expected based on domestic industry norms
(d) No evidence
• Keyword(s):
- Interlinked rule: If Employee engagement survey results is scored as
'Company tracks performance over time and takes action in response'
or 'Company discloses engagement results', Engagement surveys to
monitor employee satisfaction should not be ‘No evidence’.
- Scoring:
o Company tracks performance over time & takes action in
response - Evidence of employee survey and its mitigation
measures are given along with a comparison to previous.
Check if the company conducts regular employee surveys
and sets improvement targets. The difference between the
below credit and this one is that we give it credit only if we
see that the company tracks the performance of pervious
years, and an appropriate action is taken based on the
response over the time.
o Company discloses engagement results - if the company
discloses engagement results/score.
Child data points of Employee engagement survey results

- Company discloses engagement survey results
- Tracks engagement survey results
- Provides detailed list of areas for improvement or actionable insights
• Definition: Evaluate activities undertaken by a company as part of its
employee engagement surveys
• Keyword(s):
N/A – Checkbox
General Procedure:
- Tick “Company discloses engagement survey results” if there is a
quantitative disclosure of the results of employee engagement survey.
Note: Turnout or scope of employees that responded to the survey is not
considered here.
- Tick “Tracks engagement survey results” if there is disclosure on
monitoring of engagement results (usually in the form of charts or
tabulated) or comparison of current year with previous year’s results.
- Tick "Provides detailed list of areas for improvement or actionable
insights” if there is detailed discussion on specific areas covered by the
survey or programs developed from the survey results
Additional Guidance for Parent Data point:

- Select “Company tracks performance over time and takes action in
response” if child data points “Tracks engagement survey results” and
“Provides detailed list of areas for improvement or actionable insights” are
both ticked.
- Select “Company discloses engagement results” if only child data points
“Company discloses engagement survey results” is ticked.
- Select “No evidence” if none of the child data points are ticked.
Managerial and leadership development training

• Definition: Indicates the presence and extent of the company's managerial
and leadership development training. It should be related to managerial
and leadership for employee.
• Dropdown choices: Commented [LRA30]: Content to provide guidance on
(a) Comprehensive succession planning & development programs at dropdown choices.
multiple levels
(b) Programs focusing on internal upward mobility through training and

development
(c) General statements on leadership training with unknown scope or
achieved results
(e) No evidence
• Keyword(s):
'leadership program', 'managerial', 'training'
- This data point does not cover skills training not related to managerial
and leadership development.
- Look for evidence of training at all levels (entry + middle +
executive/top).
- Last year assessed as: Programs focusing on internal upward mobility
through training and development
Is information available this year? No information found this year
Action this year: Retain the data points and don’t mark No evidence
- Scoring:
o Comprehensive succession planning & development
programs at multiple levels –
• Clear mention of training programs. Planning for
succession is a separate policy or mention of
strategic steps to ensure succession/hiring.
• This is a two-part statement which should be
checked against disclosures:
▪ #1 Does the available training cover multiple
levels of management and/or leadership?
The disclosures should explicitly state that
the scope of training covers multiple levels
within the organization
▪ #2 Does the available training address
succession planning, development and/or
upward mobility? Company disclosures
should explicitly state that the purpose of the
training programs is to support upward
mobility, succession planning and/or
development.
• Disclosures should explicitly state the scope of the
training, whether for board, management,
executives, or all employees (temporary or
permanent); if no scope is listed the more
conservative applicable selection should be chosen.

Note that we are looking for all levels. Do not
consider evidence if it is only for board or executives
.
▪ Case 1: “Programs focusing on internal
upward mobility through training and
development” can be selected if #2 is clearly
addressed in disclosures, but no mention of
scope or coverage within the organization.
▪ Case 2: “General statements on leadership
training with unknown scope or achieved
results” can be selected if there are general
comments on leadership training without a
focus on succession planning or
development, AND there is no mention of
scope or coverage within the organization.
Child data points of Managerial and leadership development training

- Company has leadership or career development programs
- Company has internal promotion or upward mobility programs
- Company has succession planning programs
• Definition: Evaluate a company based on the managerial and leadership

development training that provides to its employees for internal growth.
• Keyword(s):
'leadership program', 'managerial', 'training'
N/A – Checkbox
General Procedure:
- Select all applicable check boxes relating to the company’s disclosure on
leadership development training
Performance - External recognition as employer of choice

External recognition as employer of choice
Do not add row if there is no evidence found.
Awarding authority name
• Definition: Indicates the name of the organization where the award came
from.
N/A - Free Text

• Keyword(s):
'awards', 'best place to work', 'best employer’
- Provide the awarding authority name
o Examples:
▪ Human Rights Campaign’s Best Places to Work for LGBT
Equality
▪ Glassdoor
▪ DiversityInc Top 50 Companies for Diversity
▪ Working Mother Magazine’s Best Companies for Multi-
Cultural Women
▪ Working Mother Magazine’s Best Companies for Working
Mothers
▪ Catalyst Award
▪ Great Place to Work
▪ Forbes
- Great Place to Work-Certified vs. Great Place to Work Best
Workplaces list - Some companies are only certified but not part
of a best workplaces list. Exclude those that are only certified.

China A
- Three international/local entities we recognized for “best employer
awards” in China:
o Note: for local awards, only include those for “best employers”, DO
NOT include those for thematic awards
o Forbes China
o Local awards:
▪ Example: Top Employers, Zhilian Zhaopin (智联招聘)
Title of the Award

• Definition: Indicates the name or title of the award given by the awarding
authority
N/A - Free Text
• Keyword(s):
- The award should be related to the company being an employer of choice.
Type of Award
• Definition: Describes the award received by the company
(a) National or international recognition as an overall Best Place To Work
(b) National or international recognition as a Best Place to Work for a
specific category
(c) Local or industry recognition as a Best Place to Work
(d) No evidence
• Keyword(s):
- Identify if the award is 'national or international recognition' or ‘local or
industry recognition'. If no information found, choose 'No evidence'
- If ‘Year’ field is updated, this data point should not be No Value.
Performance - Employees
Training & Development Table
- Add a row even if there is no evidence found.
- Training should be related to skills and professional development.
Percentage of total employees receiving training

• Definition: Indicates the percentage of employees to receive training in the
indicated year
• Keyword(s):
'training'
N/A - Numeric Input Value - in percentage
- Enter the percentage of employees receiving training in the company.
- Leave blank if no information found.
- Estimate value can be consider if there is a disclosure of Number of trained
employees.
o Number of Trained Employees divided by Total Number of Employees
* 100.
Annual training hours per employee

• Definition: Provides the average number of training hours provided per
employee in the indicated year
• Keyword(s):
'training', ‘training hours’, ‘training days’
- Always consider data for the whole company.
- Fill in wherever data is available. If the company disclosed annual training
days per employee. Please convert the annual training days per employee
into annual training hours per employee by multiplying 8 hours per day.
- Training hours per employee must make sense with respect to the possible
number of working hours per day and per year (8 hrs. per day, 5 days a
week).
- There could be a scenario wherein the company disclose Total Trained
hours. This could be used for the estimation value for the Annual Training
hours per employees.
o Annual Training hours per employee = Total Training hours divided by
Number of Trained Employees.
o Note: If there is no disclosed in Number of Trained Employees hence,
we cannot use the total number of employees except when the
company disclosed that 100% of their employee receiving training.
Training metrics include part-time/ contractors/ temporary workers

• Definition: Indicates whether training metrics include part-time workers,
contractors, and/or temporary workers or only full-time workers
(a) Yes
(b) No Evidence
• Keyword(s):
'training'
- Scoring
o 'Yes': Company also provides training to part-time/
contractors/ temporary workers.
o 'No evidence': If no information found.
Training & Development Expenditure (in USD mn)
• Definition: Indicates the amount of money (in million US dollars) the
company spent in training and development in the indicated year.
• Keyword(s):
'training', ‘training expense’
- Provide the total training & development expense expressed in million
USD
- Training and Development Expenses from the Income Statement can
be considered. But make sure that the figure would be aligned with
other indicators (e.g., training hours per employees), if disclosed. The
total expenses should make sense for the number of employees and
historical values.
-
Employee compensation, stability & productivity metrics table
- Add a row even if there is no evidence found.
Salary per employee (in USD)

• Definition: Provides the average salary per employee (in USD)
• Keyword(s):
'salary', 'wages', 'compensation', 'median'
- Compute for salary per employee by dividing salary or wages
expressed in USD to the total number of employees (i.e., full time, part-
time, and/or contractors).
- We use actual headcount for all calculations to maintain consistency.
- For the DM markets, in case there is an actual explicit disclosure of
values less than USD 20,000 as average employee salary disclosed in
AR or Proxy Reports, then those should be captured and added.
- We have only added a check for the <20,000 USD for DM markets as an
advisory since in some industries which employ many contractual staff
the total salary per employee data comes to be significantly low as the
“salaries and wages” head accounts for temporary staff salaries while
the total employee count only includes permanent staff. This issue
however affects only select industries which are manufacturing
focused and depends on the manner on which companies report the
data.
- If the company provide average monthly salary, do not multiply by 12.
We should not back calculate as it may give us over/underestimated
values.
- Do not enter zero in this field.
Employee salary data key

• Definition: Indicates whether the average salary per employee figure is
reported or estimated
(a) Average Reported
(b) Median Reported
(c) Average Estimated
(d) Median Estimated
• Keyword(s):
'salary', 'wages', 'compensation', 'median'
General Procedure:
- If Salary per employee (in USD) is greater than 0, then this data point
should not be No Value.
- Scoring
o Average/Median Reported - if recorded average/median
wage is reported by the company
o Average/Median Estimated - if recorded average/median
wage is computed by the analyst
Average annual compensation for female employees

• Definition: Provides the average annual compensation figure for female
employees at the company
• Keyword(s):
'salary', 'wages', 'compensation', 'median', ‘female’, ‘women’
- Update if the company discloses average annual compensation for
female employees. If not, leave blank.
Average annual compensation for male employees

• Definition: Provides the average annual compensation figure for male
employees at the company
• Keyword(s):
'salary', 'wages', 'compensation', 'median', ‘male’, ‘men’
- Update if the company discloses average annual compensation for
male employees. If not, leave blank.
Employee turnover category Commented [LRA31]: Pending query with Content

• Definition: Indicates whether the reported employee turnover figure Team. Below query is available in Adhoc Teams
Channel.
reflects voluntary, mandated, or unspecified turnover
• Dropdown choices: [Vendor Query]
(a) Voluntary As per content analyst, if there are multiple turnover
rates provided by the company, we will consider
(b) Mandated Voluntary turnover rate (if available) and then we
(c) Unspecified choose Voluntary turnover scoring for Common
• Keyword(s): LM/HCD. However, vendors have said that they
consider the Total Turnover Rate of the company for
'turnover', 'attrition' the same datapoint in HCD.
resign 离职; employee turnover rate 离职率
1. Should the turnover data points be the same for
• General Procedure: Common LM/HCD and HCD (for multiple turnover rate
- This should NOT be blank if Annual employee turnover (%) field is disclosures by company)? If yes, what data should be
taken for both KIs?
updated. 2. For historical data where vendors have considered
- Scoring total turnover rates and not voluntary turnover rates,
o Voluntary - when employees willingly choose to leave the should the vendors change the score of the previous
(published) years depending on the provided answer in
position/company (i.e., resignation and retirement) #1.
o Mandated - when company terminated employees (i.e.,
downsizing, redundancy, layoffs, etc.)
o Unspecified - if turnover is not specified, choose this option. Commented [LRA32R31]: From Content Team:
1. Yes, I believe the turnover data should be aligned for
Common LM/HCD and HCD. In Real Estate, we take
Annual employee turnover (%) voluntary turnover if this data is available.
• Definition: Provides the annual employee turnover (%) figure. 2. Yes, if historical voluntary turnover rates are
available.
N/A - Numeric Input Value - in percentage
• Keyword(s):
'turnover', 'attrition'
resign 离职; employee turnover rate 离职率
- Please record % turnover wherever available.
- Do not calculate employee turnover rate. Calculated values may not be
actual reflection of turnover as the total employee count may already
include the backfilled employees. It may to some extent give an
estimate turnover rate, but the calculated value may not necessarily
represent the most accurate picture of turnover rate.
- If company provides multiple turnover data, use voluntary data (if
available)
- If Employee turnover category is updated, this data point should not be
blank.

Industry Guidelines
- Sector: Financial
o If the company is consistently reporting voluntary turnover
(for last couple of years), please prioritize Voluntary
Turnover.
o If there is inconsistent reporting, please continue
prioritizing the turnover category which the company has
consistently reported (in most cases we found
Annual/Total) and indicate any deviation in terms of
reporting in the Internal Notes.
o For example – A company reported Voluntary turnover
consistently for last 4-5 years, but in the current year – it
reported total -- then please indicate the deviation in the
internal notes. This will help the content team to verify
deviation.
o For companies, that report turnover rates for the first time,
again – prioritize voluntary turnover – that is - if we have
evidence of consistent reporting (for example company
discloses past year voluntary turnover data as well). Else,
please update whatever the company reports, and indicate
the same in the internal notes. This will help the content
team to verify deviation.
o If the company has disclosed voluntary turnover for the
current year only and for the past two years total turnover
is disclosed
▪ Based on the current disclosures, we have
observed that majority of companies tend to report
total turnover. Since, voluntary turnover is less than
total turnover, including both in 3-year average is
incorrect.
▪ Retain the older trend (score) on the data point, till
we have a more consistent reporting from the
company.
▪ Please make a clear note in the internal notes
indicating that the score in Employee Turnover dp
is retained due to inconsistent reporting from the
company. This will lead to a more consistent
scoring trend and avoid sequential year volatility
Strikes, work stoppages and lockouts

Do not create a row if there’s no evidence found.
Location
• Definition: Provides the location of the labor strike, work stoppages and
lockouts.
N/A - Free Text
• Keyword(s):
'strike', 'lock-out', 'work stoppages'
- Provide the information of the location where strikes, work stoppages
and/or lockouts were experienced.
Estimated number of employees affected

• Definition: Provides the estimated number of employees affected by the
labor strike, work stoppages and lockouts.
• Keyword(s):
'strike', 'lock-out', 'work stoppages'
- Provide the estimated number of employees affected by strikes, work
stoppages and/or lockouts.
- Do not enter ‘zero’ in this field.
Community Relations - Corruption & Instability

Companies are evaluated on their commitments and conduct with respect to
violence and conflict, distribution of benefits, and the protection of human rights.
Coverage Rules
This key issue should be filled irrespective of the type of company (Lite, Full, China A)
for these industries:
• Agricultural Products • Marine Ports & Services
• Airport Services • Oil & Gas Drilling
• Aluminum • Oil & Gas Exploration & Production
• Coal & Consumable Fuels • Oil & Gas Storage &
• Copper Transportation
• Diversified Metals & Mining • Precious Metals & Minerals
• Gold • Railroads
• Highways & Railtracks • Silver
• Integrated Oil & Gas • Steel
for the following industries if Biodiversity is a weighted key issue:
• Electric Utilities
• Independent Power Producers & Energy Traders
• Multi-Utilities
• Construction Materials
• Industrial Conglomerates
Conflict and Human Rights - Policy

Company's policy indicating support for human rights
• Definition: This data point evaluates whether the company has a policy
indicating support for human rights.
a) Policy aligned with UN Declaration of Human Rights or equivalent
b) Policy adopted but no reference to international norms
c) General statements of commitment to support human rights
e) No evidence
• Keyword(s):
human rights, discrimination, harassment, UNGC, United Nations Global
Compact
人权 (human rights)
- Check in UNGC website if the company is currently a signatory.
- Look out for policies related to protection of human rights. Companies
may have their own human right policies or commitments to
international norms.
- Scoring:
o Policy aligned with UN Declaration of Human Rights or
equivalent – Select this option if a company states that they
adhere to any international norm.
• Some international norms are:
▪ Universal Declaration of Human Rights
(UDHR)
▪ United Nations (UN) Guiding Principles on
Business and Human Rights.
▪ UN Global Compact (UNGC)
▪ OECD Guidelines for Multinational
Enterprises
▪ ILO International Labor Standards
▪ EICC
• Example: Look out for phrasing such as “…is

committed to respect internationally recognized
human rights, which include the rights set out in the
Universal Human Rights Declaration and the
principles relating to the rights established by the
International Labor Organization (ILO)…” (Repsol AR
2019, p.124)
o Policy adopted but no reference to international norms –
Select this option if a company has their own human rights
policy but does not explicitly state that they adhere to any
international norm. Rarely do Chinese companies fall here
o General statements of commitment to support human
rights – Select this option if the human rights issues
discussed in the company’s human rights policy are limited
to the prevention of ‘discrimination’ and ‘harassment’. Most
Chinese issuers fall here.
norms – Don’t select this option, this is not a China A
default. Commented [LRA33]: Can be part of Audit
o No evidence – No information found.

Industry Guidelines
- Sector: Utilities
- Specific Guidelines: Score as ‘No value’
Policy on ethical business conduct with respect to violence and conflict

• Definition: This data point evaluates whether the company has a policy on
ethical business conduct with respect to violence and conflict.
a) Policy articulated
b) There is some evidence of commitment
c) Commitment stated but no policy articulated
d) Not disclosed
• Keyword(s):
human rights, violence, conflict
冲突 (conflict)、安保 (security)
- Look out for policies related to dealing with violence and conflict in
areas of operation.
- Rare on Chinese companies, maybe so for some multi-national
companies
- Scoring:
o Policy articulated – Select this option if a company has a
standalone policy regarding violence and conflict in areas
of operations. High level commitments do not equate to
policy.
o There is some evidence of commitment – Similar to
“Commitment stated but no policy articulated”. If a
company has commitments to not engage in violence and
conflict in areas of operations, but no evidence of clear
policies, opt for the more conservative approach and select
the option below.
o Commitment stated but no policy articulated – Select this
option if a company has commitments to not engage in
violence and conflict in areas of operations, but no evidence
of clear policies.
Industry Guidelines
- Sector: Utilities, Oil & Gas industries except Integrated Oil & Gas and O&G
Exploration and Production
Extension of business ethics policy to contract security providers

• Definition: This data point evaluates whether the company has a business
ethics policy for contract security providers.
a) Policy covers all security providers and compliance is ensured by audit
b) Policy covers some security providers and compliance is investigated
on an occasional basis
c) Policy covers some security providers
d) Not disclosed
• Keyword(s):
human rights, security
安保 (security)
- Check business ethics policies for coverage of contract security
providers.
companies
- Scoring:
o Policy covers all security providers and compliance is
ensured by audit – Select this option if a company’s policy
covers all security providers and compliance is ensured by
audit.
• Example: Look out for wording such as “…requires
private security companies to ensure that 100% of
the employees who work at Repsol facilities are
trained in human rights.” (Repsol AR 2019, p.65)
o Policy covers some security providers and compliance is
investigated on an occasional basis – Select this option if
a company’s policy covers some security providers and
compliance is investigated on an occasional basis
o Policy covers some security providers – Select this option
if a company’s policy covers some security providers.
Industry Guidelines
- Sector: Utilities, Transportation

- Specific Guidelines: Company’s disclosure must explicitly specify that
“ALL contract security providers across all operations and geographic
locations” must be covered by policy before it is given the highest
score. This is a very important data point for the industry, so score it
conservatively.
Distribution of Benefits - Programs

Extent of philanthropic programs to support local economic development
(hospitals, schools, infrastructure)
• Definition: This data point evaluates the extent of a company's
philanthropic programs to support local economic development (hospitals,
schools, infrastructure).
a) At least 1% of profit is invested in community development projects
addressing local needs
b) Less than 1% of profit is invested in philanthropic programs supporting
local communities
c) General statements on philanthropic programs supporting local
communities
e) No evidence
• Keyword(s):
philanthropic, community development, hospitals, schools, infrastructure
- Check if company discloses the percentage of profit invested in their
CSR.
- If the amount invested is scattered over different activities (e.g.,
education for the underprivileged, housing for marginalized groups,
vocational training for local communities, donating money to charity,
natural calamity relief funds, etc.), estimate the percentage of company
spending on such programs compared to net profit of the company.
Net profit can be found in the company’s Consolidated Balance Sheet.
- Computation: Amount of donations/ net profit * 100% = percentage of
profit invested
- Scoring:
o At least 1% of profit is invested in community development
projects addressing local needs
Less than 1% of profit is invested in philanthropic programs

o
supporting local communities
o General statements on philanthropic programs supporting
local communities - Select this option if there is evidence of
a company’s philanthropic programs but no explicit
disclosure regarding profit invested.
norms
Industry Guidelines
- Sector: Utilities
- Specific Guidelines: Score as ‘No value’. Utilities provide essential
services to people; they do not extract and export natural resources
which 'belong' to the local communities (unlike oil & gas or mining
companies).

- Specific Guidelines: Donations do not count for this data point. Give
more importance to company initiatives.
Does the company have programs to invest in philanthropic programs

supporting local communities?
• Definition: This data point evaluates whether the company invests in
philanthropic programs supporting local communities. It focuses less on
the company’s contributions to a local community’s economic
development and more on a company’s monetary contributions and
welfare projects.
a) Yes
b) No
c) No evidence
• Keyword(s):
philanthropic, community development, local communities, welfare,
contribution
- This data point is connected to the data point, “Extent of philanthropic
programs to support local economic development (hospitals, schools,
infrastructure)”. This data point must be scored along with the data
point mentioned.
- Scoring:
Yes – Select this option if a company has philanthropic

o
programs to support local communities within its area of
operations.
o No
Industry Guidelines
- Sector: Utilities
companies).
China A
- Scoring guidance: one-time donations such as in case of natural
disasters or pandemic
Does the company have programs to invest in community development

projects supporting local economic development (hospitals, schools,
infrastructure)?
• Definition: This data point evaluates whether the company has programs
to invest in community development projects supporting local economic
development (e.g., hospitals, schools, infrastructure). This data point is
focused on building projects and other economic development projects.
a) Yes
b) No
c) No evidence
• Keyword(s):
community development, local communities, hospitals, schools,
infrastructure
- This data point is connected to the data point, “Extent of philanthropic
programs to support local economic development (hospitals, schools,
infrastructure)”. This data point must be scored along with the data
point mentioned.
- Scoring:
o Yes – Select this option if a company has community
development projects within its area of operations.
o No

Industry Guidelines
- Sector: Utilities
companies).
China A
- Scoring guidance: We need project basic elements (who, what, when)
to give this credit. Also, this should be for economic projects (e.g.,
connect buyers of local food, help introduce supply chain players,
schools…) Philanthropy isn’t included here.
Job creation - local hiring

• Definition: This data point evaluates the company's support for hiring local
workers.
(a) Over 90% of workforce is local
(b) Majority of workforce is local
(c) Some efforts to hire local workers
(d) Not disclosed
• Keyword(s):
local hiring, local hire, job creation
本地化 (localization)，本地员工 (local employees)
- Check for company’s efforts in local job creation/hiring.
- Local hires should be within 50 miles within area of operations. Local
hires do not include domestic migrant workers.
- Scoring:
o Over 90% of workforce is local - need stats to give this
credit
o Majority of workforce is local - need stats to give this credit
o Some efforts to hire local workers – Select this option if
there is evidence of a company’s efforts to hire local
workers but no explicit disclosure of data.

Industry Guidelines
- Sector: Utilities
companies).
- Sector: Metals & Mining,

- Specific Guidelines: Companies usually have a high number of local
workers to begin with. Instead, if there is a granular breakdown of
workforce data, consider employees living within the province of the area
of operations as local hires.
Value of investment in community development (USD millions)

• Definition: This data point provides information the amount of investment
the company made in community development per year.
Not applicable. Tabular data point.
• Keyword(s):
community investment
- Always to be reported in USD millions.
- Scoring:
o Not applicable. Tabular data point.
Industry Guidelines
- Sector: Utilities
companies).
Community Relations - Biodiversity

Companies are evaluated on their commitments and conduct with respect to
community impact and engagement.
Coverage Rules
for these industries:
• Agricultural Products • Oil & Gas Drilling
• Airport Services • Oil & Gas Exploration &
• Aluminum Production
• Coal & Consumable Fuels • Oil & Gas Storage &
• Copper Transportation
• Diversified Metals & Mining • Precious Metals & Minerals
• Gold • Railroads
• Highways & Railtracks • Silver
• Integrated Oil & Gas • Steel
• Marine Ports & Services
for the following industries if Biodiversity is a weighted key issue:
• Electric Utilities • Multi-Utilities
• Independent Power Producers • Construction Materials
& Energy Traders • Industrial Conglomerates
Community Impact and Disturbance - Policy

Policy includes provisions on respecting indigenous peoples and
minimizing community impacts
• Definition: This data point evaluates whether the company has a policy that
includes commitments to respecting the culture, traditions, etc. of
indigenous peoples and minimizing community impact. Indigenous
peoples refer to communities that have lived in the company’s area of
operations for some generations.
a) Yes
b) No
c) No evidence
• Keyword(s):
indigenous, community impact
少数民族(minority ethnics), 本地区民（local residents）
RATINGS METHODOLOGY | MONTH YEAR
- Look out for policies related to respecting indigenous communities and
reducing community impact.
- Scoring:
o Yes – Select this option if a company includes provisions
on respecting indigenous peoples and minimizing
community impact.
o No
o No evidence – Select this option if no information is
available.
Industry Guidelines
China A
- Yes – As Chinese government doesn’t recognize the existence of
indigenous people within China, so you may find it rare by Chinese
issuers, especially for those purely operate in China. Rather they may
refer to local laws or to maximum to international standards, but this
doesn’t guarantee a such policy. However, mind that multi-national
companies may have such policies for their operations abroad.
Policy includes commitment not to operate in high conservation areas (i.e.

World Heritage sites, nature preserves, etc)
• Definition: Self-explanatory.
e) Yes
f) Minimum practices expected based on domestic industry norms
g) No
h) Not Disclosed
• Keyword(s):
World Heritage sites, nature preserves
- Look out for policies including commitments not to operate in high
conservation areas.
- Scoring:
Yes – Select this option if a company has a policy that

o
includes commitment not to operate in high conservation
areas.
norms
o No
Industry Guidelines

- Specific Guidelines: We also consider commitments to protect sacred
sites in indigenous ancestral lands and cultural heritage sites.
China A
- General Procedure:
o Yes – Look for group-wide formal/public commitment in
AR/CSR/website.
- Sector: Metals and Mining; energy sector except Oil & Gas Equipment &
Services and Oil & Gas Storage & Transportation
industry norms
- Source:
REGULATIONS OF THE PEOPLE'S REPUBLIC OF CHINA ON NATURE
RESERVES
- no industrial operations in nature reserves, however, there might be
exceptions for key communications and transportation projects that
can't bypass reserve areas due to natural condition limits

- mining activities in nature reserves and historical sites need to be
approved by the state council
Distribution of Benefits - Policy

Does the company have policy to support local supplier or local
procurement?
• Definition: This data point evaluates whether the company has a policy to
support local suppliers.
a) Yes
b) No
c) No evidence
Keyword(s):
Local Procurement Policy (LPP), local business, local supplier, local
vendor, local sourcing, local procurement, local enterprise, local supplier,
Local Vendor Policy
本地采购 (local procurement)
- Look out for a Local Purchasing Policy. This is a documented
commitment to give preference to goods and services produced and
purchased from local and independent businesses over those
produced more distantly. Also look out for amounts paid to local
suppliers.
- For Metals & Mining, no formal policy is required for the highest score.
Commitments or programs related to this data point are enough.
- Scoring:
o Yes – Select this option if the company supports local
procurement.
• Sample disclosure: “As a general rule there is a
high percentage of local procurement and
purchases, 81% of total purchases…” (Repsol IR
2019 p. 83)
o No
Industry Guidelines
- Specific Guidelines: No formal policy required for the highest score.
Commitments or programs related to this data point are enough.
Conflict and Human Rights - Programs

Does the company provide training on human rights protection for its employees?
• Definition: This data point evaluates a company's monitoring or execution
of its human rights policy. It looks at the extent to which a company
considers human rights in its operations. It also evaluates the company’s
potential to be associated with, or to be considered complicit in, human
rights abuse.
a) Yes
b) No
c) No evidence
• Keyword(s):
training + human rights policy, train + policies, employee training + human
rights
- Check SR, AR, Code of Conduct, or company website
companies
- Scoring:
o Yes – Select this option if the company provides training on
human rights protection.
o No
Industry Guidelines
- Sector: Utilities
- Specific Guidelines: Score as ‘No value’.
Does the company report its achievements against human rights targets?
• Definition: This data point evaluates whether the company reports its
achievements against human rights targets. This does not evaluate
whether the company has human rights targets.
a) Yes
b) No
c) No evidence
• Keyword(s):
human rights + target, human rights + objective
- We consider quantitative data targets only. Do not consider qualitative

data targets for this data point.
- If the company disclosure states that they committed no violations,
score Yes.
- Scoring:
o Yes – Select this option if a company reports its
achievements against human rights targets.
• Sample disclosure: “Oil Search Limited is a
participant of the Voluntary Principles on Security
and Human Rights since Dec 2016 and reports its
human rights performance results in an annual
basis.”
o No
Industry Guidelines
- Sector: Utilities
Policy includes provisions on protecting human rights

• Definition: This data point evaluates whether the company has policies
that include provisions on protecting human rights.
a) Yes
b) No
c) No evidence
• Keyword(s):
human rights + target, human rights + measure, human rights + objective
- Look out for human rights for communities in area of operations.
- Scoring:
o Yes – Select this option if a company has policies that
include provisions on protecting human rights.
o No
Industry Guidelines
- Sector: Utilities

Does the company have/set targets to monitor the human rights policy?
• Definition: This data point evaluates whether the company has targets to
monitor their human rights policy. The targets may include the coverage
in terms of assessment/monitoring of their vendors/suppliers over and
above their employees. This does not evaluate whether the company
reports their achievements against human rights targets.
a) Yes
b) No
c) No evidence
• Keyword(s):
human rights + target, human rights + measure, human rights + objective
- Check SR, AR, Code of Conduct, or company website.
- This data point is connected to the data point “Does the company
report its achievements against human rights targets?”
- Scoring:
o Yes – Select this option if a company sets targets to
monitor their human rights policy.
o No
Industry Guidelines
- Sector: Utilities
Community Impact and Disturbance - Programs

Do these initiatives represent ALL locations where the company has
operations?
• Definition: This data point evaluates whether the company’s community
engagements with local communities exists in ALL operations.
a) Yes
b) No
c) No evidence
• Keyword(s):
engagement
- Check SR, AR, or company website.
- It is recommended to answer this data point SECOND before all the
other data points under this heading.
- Scoring:
o Yes – Select this option if a company’s community
engagements with local communities exists in all
operations.
o No

China A
- Rare by Chinese issuers, even for multi-national companies. Search for
clear evidence that its policy/action plans cover all operations. If clear
evidence of policies and actions plan, yet no indication of scope,
consider giving a lower credit.
Do these initiatives represent MAJORITY locations where the company Commented [ACJ34]:
Pending to Content:
has operations?
• Definition: This data point evaluates whether the company’s community ALL and MAJORITY data points will be discussed
engagements with local communities exists in MAJORITY of all further later.
operations.
For Transportation, 50%-80% (to be discussed)
a) Yes
b) No
c) No evidence
• Keyword(s):
engagement
- Check SR, AR, or company website.
- If the data point “Do these initiatives represent ALL locations where the
company has operations?” is scored Yes, this data point must also be
scored Yes.
- It is recommended to answer this data point THIRD before all the other
data points under this heading.
- Scoring:
Yes - Select this option if a company’s community

o
engagements with local communities exists in majority of
their operations.
o No
o No evidence - No information available.
China A
- Rare by Chinese issuers, even for multi-national companies. Search for
clear evidence that its policy/action plans cover all operations. If clear
evidence of policies and actions plan, yet no indication of scope,
consider giving a lower credit.
Does such local community engagement initiatives occur through formal

channels?
• Definition: This data point evaluates whether the company has community
engagement programs, such as formal channels for grievance reporting
mechanisms or committees tasked to communicate with local
communities in their area of operations.
a) Yes
b) No
c) No evidence
• Keyword(s):
formal channel, regular engagement, regular participation, regular
consultation, regular involvement, bidirectional, partnership structure
经济社、合作社(cooperative, specialized farmers’ cooperatives, the village
economic cooperative)；本地区民（local residents）；少数民族（ethnic
minorities）
- Check SR, AR, or company website
- Look for evidence of formal or frequent communication channels for
local communities, a committee or task force in charge of
communicating with local communities, or other efforts to consult
local communities on various biodiversity, environmental, and social
issues.
- Look for evidence that the company acknowledges the potential
impacts of its operations, takes responsibility, and works with
communities to prepare for and manage these.
- Scoring:
o Yes - Select this option if a company has a committee of

task force to communicate with local communities.
• Sample disclosure: “At OMV, human rights
grievances from community members and suppliers
are submitted through the Community Grievance
Mechanism, and then analyzed locally and at Group
level. … OMV has assessed its Community
Grievance Mechanisms against the UN
Effectiveness Criteria at OMV Petrom, in Austrian
Upstream operations, and at the Austrian refinery in
Schwechat and has started an assessment at the
Burghausen refinery in Germany. This involves
consulting our external stakeholders about the
effectiveness of the available grievance channels.”
(OMV Aktiengesellschaft 2019 SR, p. 99)
o No

China A
- this data point should be linked to the option for the data point “Does
the company have local community engagement programs (such as
grievance reporting mechanisms, disputes mechanisms)?”, for which is
any credit is given, should mark as ‘Yes’ for “Does such local
community engagement initiatives occur through formal channels?”
Does the company have local community engagement programs (such as

grievance reporting mechanisms, disputes mechanisms)?
• Definition: This data point evaluates whether the company has an
adequate internal procedure to process claims/issues externally raised by
local communities in their area of operations.
a) Precautionary approached with ongoing impact monitoring process and
formal channels (grievance mechanisms) for local community
engagement.
b) Reactive approach focused on addressing existing community concerns
c) General statements on supporting community engagement programs
d) No evidence
• Keyword(s):
grievance, dispute
- This data point does NOT refer to hotlines for ethics violations.
- It is recommended to answer this data point FIRST before all the other
data points under this heading.
- Grievance websites/hotlines are generally scored as reactive, but if the
company has specialized hotlines for each country/region, give highest
credit.
Industry Guidelines
- Sector: Metals & Mining and Transportation
o Give highest scoring only if they have formal channels (e.g.
committees with representatives from local communities,
platforms with local leaders, regular engagements) at ALL
sites.
o Grievance websites/hotlines are generally scored as
“Reactive approach”.
o Hotlines for each country/region, give highest credit.
Does the company state that it engages with the local community where it
has operations?
• Definition: This data point evaluates whether a company engages with
local communities in its area of operations.
a) Yes
b) No
c) No evidence
• Keyword(s):
engagement
实地走访 (on-site visits, field study and visits); 社区交流 (community
communication/exchange activities); 电话沟通：(phone calls); 经济社、合
作社（ cooperative, specialized farmers’ cooperatives, the village
economic cooperative）; 本地区民（local residents）；少数民族（ethnic
minorities
- Scoring:
o Yes – Select this option if a company engages with local
communities in its area of operations.
o No
Company conducts community impact assessment prior to settling in new

areas
• Definition: This data point evaluates whether the company follows the
principles of Free, Prior and Informed Consent (FPIC), or whether the
company engages with the local communities before settling in new
locations.
a) Company applies the principles of Free, Prior and Informed Consent
(FPIC)
b) Evidence of community engagement prior to settling in new locations
(5)
c) Not Disclosed
• Keyword(s):
engagement, community, FPIC, social impact assessment
社区影响、意见征询： (impact consultation); 经济社 (cooperative,
specialized farmers’ cooperatives, the village economic cooperative)
- Please be noted: This datapoint must be scored consistently with the
same data point in Biodiversity & Land Use.
o If BLU data point is Yes, this data point must be scored
either “Company applies the principles of Free, Prior and
Informed Consent (FPIC)” or “Evidence of community
engagement prior to settling in new locations (5)”
- Scoring:
o Company applies the principles of Free, Prior and Informed
Consent (FPIC) – Select this option if FPIC is explicitly
mentioned as it’ is a special process especially with
indigenous peoples. Otherwise, score as
o Evidence of community engagement prior to settling in
new locations
• Sample disclosure: “We start by conducting a Social
Impact Assessment (SIA), which includes free and
prior informed consultation with and consent of
local stakeholders.” (OMV Aktiengesellschaft 2019
SR, p. 105)
new locations (5)

Industry Guidelines
- Sector: Utilities
- Specific Guidelines: Should be scored
China A
- Scoring:
o Company applies the principles of Free, Prior and Informed
Consent (FPIC) – rare on Chinese issuers, since even the
Chinese government is criticized by global community for
not doing so (which is partially due to its centralized and
strong planning power). Only give this credit if the company
provides clear statement that it applies this principle and
gives anecdotes in this regard.
new locations - by some Chinese issuers. Give this credit it
the company provides anecdotes.
Consumer Financial Protection

This Key Issue evaluates financial institutions’ product stewardship and
transparency, including efforts to mitigate potential reputational and regulatory risks
arising from unethical lending practices or mis-selling financial products to
consumers. Companies that have governance structures to oversee and respond to
customer complaints, and financial stewardship programs to engage with customer
score higher on this Key Issue.
Sources:
• Annual Report/10K • Company website
• ESG/Sustainability/CSR report • Debt collection/ recovery policy
• Advertising/ Communication/ • Customer Charter
Lending practices • Grievance redressal mechanism
• Complaint Websites
Performance
Customer Complaints
• Definition: Assess the customer complaints (i.e., YoY, market and industry
averages, and rank in the market)
(a) Complaints decreased by more than 10% year-on-year
(b) Complaints rank among lowest in market
(c) Complaints rank near expected market and industry averages
(d) Not disclosed
(e) Complaints rank among highest in market
(f) Complaints increased by more than 10% year-on-year
• Keyword(s):
'complaints'
- Set to No Value as this is a discontinued data point.
Performance – Complaints
Complaints Table
Do not create a row if there’s no evidence found.
Number of Complaints, # of Resolved Complaints, and Resolution Rate

• Definition: Indicates the total number of consumer complaints.
• Keyword(s):
'complaint'
- Find number of complaints, # of resolved complaints, and resolution
rate in AR, SR, or company website.
- If Resolution Rate is not reported, compute by dividing the number of
resolved complaints by number of complaints and multiply to 100.
Location Website Name

Australia Australian Financial Complaint Authority
India Reserve Bank of India
United Kingdom Financial Conduct Authority
Financial Ombudsman Service
United States Consumer Financial Protection Bureau
- Prioritization Procedure - AR/CSR vs Ombudsman Websites (e.g.,
CFPB, FCA, etc.)
o Companies in US and UK: Prioritize CFPB or FCA disclosed
complaint data over self-reported data.
o Companies in Australia: Prioritize self-reported data over
AFCA disclosed annual data.
o Companies in India: Prioritize self-reported data over RBI
annual data.
Industry Guideline
- US Issuers:
o Check the data in Consumer Financial Protection Bureau
(CFPB) website
o Select date range (e.g., From 1/1/2021 Through
12/31/2021) and type in the company’s name in the
“Company name” section.
o Use the ‘Company response to consumer’ section to update
the # of Resolved Complaints. Note that only the categories
marked as ‘Closed’ (e.g., ‘Closed with explanation’, ‘Closed
with monetary relief’, and ‘Closed with non-monetary relief
should be counted as resolved.
o Do not consider ‘Ultimately response’ and ‘In progress’ in #
of Resolved Complaints.
o If data is not available, update using the company

disclosure from AR/CSR/website.
- UK Issuers:
o For issuers with country of incorporation, GB, check the data
in Financial Conduct Authority (FCA) website.
o Data from FCA website should be prioritized. This is
because FCA disclosures will follow a more standardized
reporting as this is regulated and will fix nuances from
inconsistencies in individual company reporting.
o Consider only items under ‘Opened’ category and sum the
data of 1st and 2nd half of the year.
o Do not enter items under ‘Closed’ category in the # of
Resolved Complaints field. Leave it blank.
o If data is not available, update using the company
disclosure from AR/CSR/website.
- AU Issuers:
o Ombudsmen in other countries usually disclose based on
calendar year, so for Australia we should prioritize self-
reported data over AFCA data.
o No need to change published data.
o If company does not disclose any complaints data in its
AR/CSR, we can use the AFCA number but need to put a
note clarifying the coverage period.
o Please put coverage period in the Details column if using
AFCA data, e.g., “07/01/2020 - 06/30/2021” for Year 2021
Performance – High Risk Loans

NOTE: Do not update the data points under this section.
Value of loans with LTV>90% (most recent year)

•Definition: Indicates the value of loans with loan-to-value greater than
90%.
• Keyword(s):
'LTV', 'loan-to-value'
• General Procedure: (Do not update this data point)
- Enter the loan-to-value greater than 90%. Usually found in notes of
Annual Report/Financial Statements. If no information found, leave
blank.
Total value of residential mortgage loans (most recent year)

• Definition: Indicates total value of residential mortgage loans (most
recent year)
• Keyword(s):
'mortgage loans'
- Enter the total value of residential mortgage loans. Usually found in the
breakdown of loans.
High-risk housing loans

• Definition: Indicates the company's high-risk housing loans.
• Keyword(s):
'housing loans'
- Enter the sum of all high-risk housing loans (including above
categories)
- Exclude loans with LTV>90
High-risk consumer loans

• Definition: Indicates the company's high risk consumer loans.
• Keyword(s):
'consumer loans'
- Enter the sum of all high-risk consumer loans
- Other High-Risk Consumer Loans such as Home loans, Refund
Anticipation Loans, Payday Loans, Payroll loans, Subprime Student
Loans, Student Credit Card Loans and Subprime Auto Loans can be
considered.
Practices
Product/Service Reviews
▪ Does the company conduct product and service related reviews?
▪ Does the company describe the reporting line of such reviews?
▪ Is there a Management Level Committee that has oversight of
product/service reviews?
▪ Is there a Board level committee that has oversight of product/service
reviews?
• Definition: Indicates if the company has product and service reviews,
reporting lines or committees for such reviews.
(a) Yes
(b) No [Please do NOT choose this option]
(c) No Evidence [Please always choose this option when you couldn’t find related
disclosures]
• Keyword(s):
'risk management’, ‘service review’, ‘consumer review’, ‘product review’,
‘consumer protection’
- Search for Risk Management Framework, Service Review, Consumer
Review, Product Review, or Consumer Protection on AR/CSR Report.
- Aside from AR/CSR, check the charters document (i.e., audit committee
charters, nomination committee charters) which describes the roles and
responsible of various committees. They would also include products and
services reviews in these documents.
- Also check the governance page to find evidence of products/services
review.
- Does the company conduct product and service-related reviews? – if
there is evidence found for this data point, search who has the oversight of
product/service reviews and then answer below dps based on the
disclosure.
o Is there a Board level committee that has oversight of
o Is there a Management Level Committee that has oversight of
- Management Level Committee – includes executive (e.g., CEO, COO, or
credit risk officer). Separate product-service or product safety committee
can be also considered here.
- Does the company describe the reporting line of such reviews? – this is a
rare datapoint but if reporting line of the committee that reviews the
products/services is disclosed, mark this datapoint as yes.
• Where to find:
- Annual Report, CSR Report, Committee Charters
Process for Handling Complaints

• Definition: Describes the company's process of handling complaints
(e.g., thru customer ombudsman and/or internal complaint
committee, and complaint hotlines)
(a) Customer Ombudsman & Independent internal complaint review body
with well-defined procedures and/or targets
(b) Independent internal complaint review body with well-defined
procedures and/or targets
(c) Complaint hotline, with internal complaint reviews
(d) Complaint hotline
(e) No evidence
• Keyword(s):
'complaints', ‘Ombudsman’, ‘complaint review’, ‘hotline’
- Company must have an independent internal review body to score ‘a’
or ‘b’ which means there is a standalone department/team
responsible for complaint reviews, not sales/client services
employees.
- Give full credit when company has both independent internal review
body AND an Ombudsman, who can be internal (company’s final
appeal body customers can turn to if their complaints haven’t been
resolved) OR external (country’s financial ombudsman).
- Check for company website (Complaints section), check for internal
complaints committee or hotline. And, if the company mentioned that
they are not able to resolve or escalate the issuer, then there is a
customer ombudsman.
- Also check the company’s codes and policies. Sometimes a separate
Ombudsman scheme document is uploaded (check the corporate
governance section on website).
- AR/CSR report keyword search. If no information in AR/CSR report,
check whether country of domicile has a financial services
ombudsman.
- Select countries with financial services ombudsman:
United States Brazil Canada
South Africa Australia Germany
Switzerland United Kingdom New Zealand

India Malaysia
For companies in those countries, we still need to check
o
whether they have an internal complaint review process to
give credit.
o For example, if a company domiciled in US but doesn’t have
any complaint hotline or internal complaint review, we
would score it as “No evidence”.
o Meanwhile, if a company domiciled in US and we found
evidence of independent internal review body, then we
would give top credit without checking for ombudsman
(because we know there’s CFPB in US).
- Process for Handling Complaints vs Practices related to investigating
and addressing complaints of mal-administration or a violation of
rights
o These two are NOT interlinked data point. Please
make sure to score the “Process for handling
complaints” indicator independently.
o The “mal-admin” one is old/inactive indicator which
would be removed. But pls keep scoring it as long as
it’s getting reflected in Capture.
Oversight of Complaints
•Definition: Indicates if complaints are reviewed by a
group/committee, and if so, whether the company discloses the
reporting line.
(a) Board level committee with oversight of complaint reviews
(b) Management level committee for complaint reviews reports to the
board
(c) Process or group for complaint reviews, no disclosure on reporting lines
(d) Some evidence of complaint reviews
(e) No evidence
• Keyword(s):
'complaint management’, ‘complaint review’, ‘complaint procedure’,
‘process for complaints’, ‘complaint oversight’, ‘complaint’
- We need to ask the questions below when scoring this data point:
o Are there complaint reviews?
o If yes, does the company describe the reporting line?
- AR/CSR report keyword search.
- Process of Handling Complaints vs Oversight of Complaints

o Process of Handling Complaints – talks about how the
company is resolving the complaints
o Oversight of Complaints – comes into place once the
complaints are resolved. For this datapoint, we need to
check if the company has committee to review and assess
the complaints received. In this case, they can create
procedure to reduce the number of complaints.
- Scoring:
o Management level committee for complaint reviews
reports to the board – explicit disclosure of reporting line
(i.e., board) is not needed to use this option as sometimes
there will be no disclosure regarding the reporting line. If
there is a disclosure about management level committee
and no evidence on reporting line, then use this option.
o Some evidence of complaint reviews – if an officer or a
head of business who have oversight responsibilities but is
not part of a committee then, use this option.
Financial Education Initiatives and Stakeholder Outreach

▪ Evidence of company educating its customers only through online channels?
▪ Does the company partner with financial education providers with an aim to
improve financial literacy of its stakeholders?
▪ Evidence of company imparting financial literacy to its customers by way of
providing reading material / literature?
▪ Is there evidence that the company adopts differentiated financial literacy
strategies for different demographics?
▪ Evidence of the company educating customers face to face/in person with an
aim to impart financial literacy? [webinars or other kinds of interactive sessions
are also considered “face to face” education]
▪ Evidence of company imparting financial education from accredited
institutions to customers via multiple platforms?
• Definition: Financial education is the process by which financial

consumers/investors improve their understanding of financial
products, concepts, and risks, and through information, instruction
and/or objective advice, develop the skills and confidence to become
more aware of financial risks and opportunities, to make informed
choices, and to take other effective actions to improve their financial
well-being.
(a) Yes
(c) No Evidence [Please always choose this option when you couldn’t find
related disclosures]
• Keyword(s):
‘financial education’, ‘Outreach’, ‘Financial Literacy’, ‘Consumer Education’
- NOTE: This should be a training for Financial Literacy/financial
education Programs. Please do not give credit for other general
trainings or digital literacy.
o Educating on the products available and how they can achieve
financial goals through those products.
o Areas that deserve credit include
▪ engagement with target audience during product
development, for example through surveys
▪ initiatives to raise awareness and improve
understanding of products
▪ initiatives to provide consumers with greater access to
sources of information about financial products, for
example by providing translation in local languages
▪ Partnerships with NGOs, government & local businesses
at any stage of the product development & sales cycle
- Multiple Platforms
o Examples of Multiple platforms: online, classroom-based,
available video on their website, dedicated learning page for
large, diversified companies or link to learning platforms where
videos will be hosted.
o Learning material like in consumer finance. If they give to the
customer specifically an information on what kind of mortgage
they should go for or what are the terms they should sign off to
borrow money with the financial institution (e.g., FHA in USA).
- Face to Face / In Person
o Company educating customers face to face/in person with an
aim to impart financial literacy – these are webinars or other
kinds of interactive sessions are also considered “face to face”
education.
▪ if not explicitly disclose if it is online or face to face,
hosting a seminar or classroom training can be
considered here.
oIndividual from the company who is educating customer

available face to face (online video) or in person they would
provide a specialize dedicated boxes in their annual / CSR
report which they had organized certain session with specific
set of numbers of individual or community and their employee’s
agenda-able financial literacy.
o Note: For COVID situation - Check if previously disclosure was
face to face and move to online platforms and if not Retain
scoring.
- Online Channels
o Company educate customer regarding its product or service
types of loan or deposit through online channel (Online /
Digitally information) generally on the point of financial
planning or literacy.
o Online Channels should be recognized by Partnerships with
NGOs, government, active institution & local businesses at any
stage of the product development & sales cycle.
o Note: Basic Information we cannot marked as Yes. Make sure
to have a detailed financial literacy.
o Check the company website as well, look at the individual
option (ex. Loan in Learning Center) wherein they provide you
financial product. When you click on those, they will provide you
more information like pdf guidance on how to select a product
within that they will describe the product the aim of that
product. Some of the information that would help the customer
make more financial savvy and will inform them to choose
wisely.
- Reading Material/Literature
o If available PDF or brochures or Blogs under the financial
products specifically that would enhance the knowledge of the
customer and more detailed on financial planning that are
written materials e.g., on how to decide when to mortgage.
- For Stakeholder
o This can be described as potential customers/people. This not
limited to current customers of the company. If they have
financial literacy training programs or financial education with
people who are not the customer as of now.
o Examples of outreach / financial education organization.
▪ Junior Achievement (Teenage Focus)
▪ Junior Achievement China & Hang Seng Bank
▪ My Classroom Economy
▪ Catalyst
▪ EverFi
▪ National Financial Educators Council
▪ Brain Arts Production
▪ Prosper Canada
▪ New York Institute of Finance
- For Different Demographics
o How the company is adapting different strategies to make them
aware of different types of financial literacy or concept or
product.
o How the company address on different types of people and
communities. This may also include potential customers
(Stakeholders).
o This can be different languages, gender, ethnicity, and age in
financial knowledge.
▪ Example: Specifically in women empowerment to
improve their financial literacy.
▪ Example: Initiatives to provide consumers with greater
access to sources of information about financial
products, for example by providing translation in local
languages
▪ Where to find:
Annual Report or CSR Report → search words:
Financial Education Financial Literacy
Outreach Consumer Education
Debt collection policy

• Definition: Describes the company's debt collection process.
(a) Standalone debt collection policy with well-defined procedures, and
training for relevant employees
(b) Debt collection policy incorporated in broader policy with training
provided to relevant employees
(c) Debt collection policy without training for relevant employees
(d) General statements on debt collection practices
(e) Not disclosed
• Keyword(s):
'collection’, ‘collection procedure’, ‘debt collection’, ‘responsible collection’,
‘collection process’, ‘loan recovery’
- We need to ask the question below when scoring this data point
o Does the company provide guidance to manage debt
collection practice, to ensure they are in line with local
regulations or industry norms?
- Best practice is a separate written policy that lays out specific
processes a debt collection officer must follow; some details may
include ‘do not contact customer after 9pm, before 6am or on
weekends’, explaining the rights of the customers, how to
communicate with different kinds of customers.
- Policy should be followed by all employees involved in debt collection
and their managers.
- Internet search: “[Bank Name] + Collections”
- Where to find: Annual report or CSR report or Code of conduct
- Scoring:
o Standalone debt collection policy with well-defined
procedures, and training for relevant employees – Some
companies have standalone debt collection policy meaning
they have separate policy. Common in Indian banks. Check
the code and policies section on the website.
o Debt collection policy incorporated in broader policy with
training provided to relevant employees – For smaller
banks, the policy could be incorporated in other policies
such as Code of Conduct, Fair Advertising policy, etc.
Fair Advertising Policies/Procedures

•Definition: Indicates the company’s fair advertising/marketing/sales
policies or procedures
(a) Standalone advertisement policy with an oversight body, and training
for relevant employees
(b) Advertisement policy incorporated in broader policy with oversight body
and training provided to relevant employees
(c) Advertisement policy with either oversight committee or employee
training
(d) Advisement policy with no mention of oversight committee or employee
training
(e) Not disclosed
• Keyword(s):
‘advertising policy’, ‘marketing policy’, ‘marketing’, ‘responsible marketing’,

‘advertisement policy’, ‘responsible advertisement’, ‘responsible
promotions’, ‘sales conduct’
- We need to ask this question when scoring this indicator:
o Within the context of retail customers, does the company
provide centralized guidance and policies on
advertisement to avoid negative practices?
- Fair advertisement policies focus on transparency, fairness, honesty,
and oversight. They may be presented in other names, such as
“Solicitation Policy” or “Financial Promotions Policy” – if those policies
aim at providing employees guidelines toward sales/marketing
practices and avoiding misleading information, we should give
companies credit on this indicator.
- If advertisement policy does not mention any ethical considerations
such as transparency, honesty, fairness – choose last option before no
evidence.
- Training may be provided as part of broader ethical training.
- Oversight may include reviews of advertisements by dedicated or non-
dedicated body of employees who can raise ethical concerns before ad
is published.
- Internet search: “[Company Name] + Advertising Policy” or “[Company
Name] + Marketing Policy”
- Where to find: Annual Report or CSR Report or Code of Conduct
Search words:
o Marketing
o Responsible Marketing
o Advertisement Policy
o Responsible Advertisement
o Responsible Promotions
o Sales Conduct
- Scoring:
o Standalone advertisement policy with an oversight body,
and training for relevant employees – Some companies
have standalone advertisement policy meaning they have
separate policy.
o Advertisement policy incorporated in broader policy with
oversight body and training provided to relevant
employees – For smaller banks, the policy could be

incorporated in other policies (e.g., Code of Conduct)
- Training for relevant employees – Relevant employees include
bankers and customer-facing employees. Customer-facing employees
are included in the training to mitigate the risk of product mis-selling.
- Two types of advertising policies disclosures
o For products/services – this should be considered for this
data point.
o Price sensitive information – do not consider this for this
data point.
Whistleblower protection
• Definition: Indicates if the company has procedures to protect
whistleblowers from retaliation
(a) Independent protected resolution systems for allegations of retaliation
and specific training about internal and external protection programs
(b) Independent protected resolution systems for allegations of retaliation
(c) General whistle blower protections articulated; limited disclosure on
training or resolution systems
(d) No [Please do NOT choose this option]
(e) No Evidence [Please always choose this option when you couldn’t find
• Keyword(s):
‘whistleblower’
- Focus here is on whether programs exist to protect whistleblowing, and
whether those programs are being communicated to employees.
- Best case scenario would be standalone processes to investigate
retaliation of whistleblowing and specific training to teach workers
their rights and about available internal & external protection programs,
and for managers to learn these along with related skills, behaviors, and
obligations to act.
- Internet search: “[Bank Name] + whistleblowing policy”
- This data point is the same as the Provision of whistleblower protection
under Corporate Behavior.
• Where to find:
- Internet search words:
“[Company name] + Whistleblowing policy”
- Annual report or CSR report or Code of conduct → search “Whistleblow”
- Check code and policies on the company website
Loan modification options

•Definition: Indicates if the company provides loan modification
options
(a) Well-defined loan modification options that include income-based
considerations and customer access to escalation options
(b) Loan modification options with income-based repayment
(c) Loan modification options with customer access to escalation options
(d) Loan modification options available, limited information on types or
scope of options
(e) No evidence
• Keyword(s):
‘Customer Assistance’, ‘Refinancing’, ‘Forbearance’, ‘Loan Modification’,
‘Homeowner Assistance’, ‘Mortgage Modifications’
- Types of modification options:
o forbearance (giving a break from payments),
o monthly payment adjustments,
o income-based repayment,
o interest rate adjustments,
o interest rate reduction,
o loan extension,
o partial claim,
o principal deferral,
o reinstatement,
o repayment plan,
o short sale,
o interest rate deferral,
o deferral, and
o refinancing.
- For Western European, North American companies – select ‘minimum
practice’ if no other evidence is found.
- Interlinked with ‘Evidence of loan modification program or other
programs to assist customers facing financial difficulties’ data point.
This data point should not be ‘No evidence’ if ‘Evidence of loan
modification program or other programs to assist customers facing
financial difficulties’ is scored as ‘Yes’
- Event Related Disclosures (e.g., COVID)
o Due to specific events like COVID, banks are offering more

enhanced loan modification. We SHOULD NOT give credit
beyond option (d) Loan modification options available,
limited information on types or scope of options.
o Since these types of disclosures as these are only
temporary. These loan modification options will be
discontinued once the situation is normalized.
• Where to find:
- Company home page
- Annual Report or CSR Report → search words:
Customer Assistance Refinancing Homeowner Assistance
Loan Modification Forbearance Mortgage Modifications
Employee training on consumer financial protection

• Definition: Indicates if the company provides consumer protection
training for customer-facing employees
(a) Training provided annually to all relevant customer-facing employees
(b) Training provided to some customer-facing employees
(c) Consumer financial protection related content in annual ethics or
compliance training
(d) Some evidence of consumer financial protection training provided
unknown scope
(e) No evidence
• Keyword(s):
‘Consumer Protection’, ‘Customer Service’, ‘Vulnerable Customers’,
‘Financial Education’, ‘Responsible Banking’, ‘Customer Relations’,
‘Responsible Lending’
- It may be called ‘customer relations’, ‘fair treatment’ or broadly
‘customer service’ training.
- CFP training includes non-discrimination and fair treatment of
customers, anti-fraud and fraud misuse training, review of local
consumer protection legislation.
- Give full credit when company provides detailed instructions in a
standalone policy and training is conducted at least annually for all
customer-facing employees.
- If code of conduct/ethics refers to consumer protection, responsible

customer communications, or something similar AND states that
employees must complete a training exercise on the content of the
code
- Customer Product Safety vs Consumer Financial Protection
o Customer Product Safety
• subset of Customer Financial Protection
• topics related to product safety to avoid mis-selling
of products
o Consumer Financial Protection
• Does not only include product safety but include
other topics like non-discrimination/fair treatment
of customers.
• Where to find:
Annual report or CSR report or Code of conduct or Code of ethics → search
words:
Consumer Protection Customer Service Responsible Banking
Responsible Lending Vulnerable Customers Customer Relations
Practices
The indicators below currently are not feeding into the CFP KI score, but we still need
to collect/update them for the short term as issuers are able to see them.
Evidence of employee training on customer product safety

•Definition: Indicates if the company has training on customer product
safety
(a) Yes
(b) No evidence
• Keyword(s):
‘consumer safety’, ‘product safety’, ‘consumer protection’, ‘training’
- This data point is a discontinued indicator, but we SHOULD continue to
update this as it is available in ICP portal.
- Training provided to employees to avoid mis-selling of products.
- If there is any training in the fair advertising policy, then mark this
datapoint as Yes.
- Customer Product Safety vs Consumer Financial Protection
o Customer Product Safety

• subset of Customer Product Safety
• topics related to product safety to avoid mis-selling
of products
o Consumer Financial Protection
• Does not only include product safety but include
other topics like non-discrimination/fair treatment
of customers.
Evidence of Consumer Charter

• Definition: Indicates if the company has a consumer charter.
Consumer charter is a written policy that expresses the company's
commitment to doing business with others (i.e., customers). It covers
the company's rules, procedures, and service level agreements (SLAs)
with their consumers.
(a) Yes
(b) No evidence
• Keyword(s):
'consumer charter’, ‘customer charter’
- This data point is a discontinued indicator, but we SHOULD continue to
update this as it is available in ICP portal.
- Score if the company has consumer charter in their reports/website.
JP IMI
- Industry: All
- Source: https://www.fsa.go.jp/policy/kokyakuhoni/kokyakuhoni.html
Evidence of hotline for customer complaints

• Definition: Indicates if the company has hotline for customer
complaints.
(a) Yes
(b) No evidence
• Keyword(s):
'hotline’, ‘helpline’
- Score if evidence of company providing a hotline for customer

complaints or company has policy on addressing customer complaints
- Should be 'yes' if the score of Process for Handling Complaints is either
'Complaint hotline, with internal complaint reviews' or 'Complaint
hotline' Commented [LRA35]: This procedure can be used
• Guidelines for Specific Industry / Market while profiling.
China A
Pending Item: Data Ops to create validation rule.
- Sub-Industry: Banks, Thrifts & Mortgage Finance, Other Diversified
Financial Services
JP IMI
- Industry: All
- Source: https://www.fsa.go.jp/policy/adr/index.html
Evidence of loan modification program or other programs to assist

customers facing financial difficulties
•Definition: Indicates if company has loan modification program or
other programs to assist customers facing financial difficulties.
(a) Yes
(b) No evidence
• Keyword(s):
'Customer Assistance’, ‘Refinancing’, ‘Forbearance’, ‘Loan Modification’,
‘Homeowner Assistance’, ‘Mortgage Modifications’
- Types of modification options:
o forbearance (giving a break from payments),
o monthly payment adjustments,
o income-based repayment,
o interest rate adjustments,
o interest rate reduction,
o loan extension,
o partial claim,
o principal deferral,
o reinstatement,
o repayment plan,
o short sale,
o interest rate deferral,
o deferral, and
o refinancing.
- Interlinked with Loan modification options data point. If this data point
is scored as ‘Yes’ therefore, Loan modification options should not be
no evidence.
Company partners with financial counselors or relevant community

organizations
•Definition: Indicates if the company partners with financial counselors
or relevant community organizations
(a) Yes
(b) No evidence
• Keyword(s):
'counselor' 'advisor', 'assistance' 'safety', 'product safety', 'financial
protection'
- Score if company has a partnership with any financial counselors or
any related organizations who help them to assist customers for
financial advice or financial safety.
- This datapoint is related to financial literacy or financial inclusion. We
are looking for financial advisors or external parties extending their
knowledge on financial product/planning or digital financial literacy.
- Example: Community forums reaching out to underserved
market/community.
Sales Targets
▪ Are sales targets of customer service representatives linked to monetary
compensation?
▪ Does the company have quantitative/volume-based sales targets for
customer service representatives?
▪ Are sales targets of managers of customer service representatives linked
to monetary compensation?
▪ Does the company have quantitative/volume-based sales targets for
managers of customer service representatives?
• Definition: Customer service staff would be the front-line staff tasked with
answering client queries. There is a conflict of interest when they are also
tasked to sell products/services to customers. Quantitative targets for
sales for customer service reps or their managers is the worst-case
scenario if the targets are taken into account in consideration for bonuses,
or the employees’ overall performance. Sales incentives may include
bonuses for high sales or gifts, non-financial incentives such as company

recognition or additional vacation time. .
(a) Yes
(c) No Evidence [Please always choose this option when you couldn’t find
• Keyword(s):
'risk management’, ‘service review’, ‘consumer review’, ‘product review’,
‘consumer protection’
- Worst case scenario during profiling: Quantitative sales target for
customer representatives or their managers are considered for
bonuses or the employees' overall performance.
- Banks should provide disclosures whether the variable pay of their
sales employees or employees who are customer facing are linked to
the sales target. Examples: (1) In their variable pay, there is monetary
compensation linked to sales target. (2) customer facing employees
have variable remuneration linked to how they provide service to
customers.
- Sales incentives may include bonuses for high sales or gifts, non-
financial incentives such as company recognition or additional
vacation time
- Internet search: “[Company Name] +…” or AR/CSR keyword search:
o Sales goals
o Upsell
o Sales practice
o Sales targets
Ownership of product safety compliance oversight

• Definition: Indicates the dedicated committee to oversight
product safety compliance and to whom this committee reports.
(a) Dedicated product safety committee reports directly to the board
(b) Dedicated product safety committee, reporting lines unclear
(c) Evidence of product safety reviews, but ownership and reporting is
unclear
(d) No evidence
• Keyword(s):
'consumer safety’, ‘product safety’, ‘consumer protection’
- Score if the if the company conducts product safety reviews that are
overseen by a dedicated committee.
- Check to whom this committee reports.
- In AR/CSR (complaints related section), code of conduct or advertising
policy (if there is a separate disclosure), there will be discussion about
product safety. Check for product safety compliance oversight.
- Product safety compliance oversight – this is an oversight on the
implementation of product safety. This the committee who executes
the product safety.
Practices related to investigating and addressing complaints of mal-

administration or a violation of rights
• Definition: Indicates if the company has customer ombudsman
and/or internal complaints to address issues of mal-administration or
a violation of rights
(a) Customer Ombudsman and internal complaints resolution department
(b) Customer Ombudsman
(c) Internal complaints resolution department
(d) No evidence
• Keyword(s):
'complaints', ‘Ombudsman’, ‘complaint review’, ‘hotline’
- Evaluates the complaint resolution mechanism employed by the
company. We evaluate the customer relationship management and
grievance mechanism systems of entities like banks, insurance
companies.
- Do not consider the whistleblower if it is limited to the employees only.
Please make sure that the scope of the policy is extended to the
customers. If the policy includes customers, then that’s the only time
we can use the evidence and mark this data point as yes.
Industry Guideline
- FR: Customer Ombudsman
- IT: Internal complaints resolution department
China A
- Sub-Industry: Banks, Thrifts & Mortgage Finance, Other Diversified
Financial Services, Insurance Brokers
- Default Scoring: Customer Ombudsman
JP IMI
- Industry: All
- Default Scoring: Internal complaints resolution department

- Source: JP IMI Regulation: Financial Instruments and Exchange Act
Exposure – Reliance on Consumer/Retail Business Segments

Retail and/or consumer loans as % of total loans Commented [LRA36]: The procedure indicated under
• Definition: Indicates the percentage of retail and/or consumer loans the data point name can be used while profiling.
of the company
• Dropdown choices: Pending with Ops and Content Teams.
N/A - Numeric Input Value This should be aligned with Exposure – Loan Table.
• Keyword(s): Loan table Add all retail loans and divide to the total
'retail', 'consumer', 'individual', 'loans' loans.
Issues:
- Typical examples of retail loans include mortgage loans, consumer 1.Clients – query regarding alignment of Exposure –
loans, credit cards and personal loans. loan table and Ops – Loan dps.
2.Loan table is not available in Data Ratings form
- Exclude Loans to SMEs for this calculation. Express this as a % of
and to the vendor.
the Gross Loans at the end of the financial year.
- Refer consolidated balance sheet figures, rather than stand-alone To be raised with Gino and Von.
balance.
- The aggregate of % of retail loans in this key issue and % of
Corporate commercial loans in Financing Environmental Impact
adds up to 100%.
Controversial Sourcing
This issue evaluates the extent to which companies may face regulatory risks,
reputational damage, or supply-chain disruptions due to sourcing raw materials from
areas associated with human rights and labor abuses. Scores are based on reliance
on controversial raw materials (e.g., conflict minerals); sustainable sourcing
practices and certification; and controversies.
Practices
Scope of the policy to address sourcing and use of raw material that may
originate from areas associated with severe human rights, illicit trade, and
financing of violence
• Definition: This data point pertains to the scope of the policy to address
sourcing and use of raw material that may originate from areas associated
with severe human rights, illicit trade, and financing of violence.
(a) Company's responsible sourcing policy extends to materials not
currently covered by international mandates (e.g., cobalt, colored gems)
(b) Company belongs to an industry organization (e.g., EICC, Responsible
Jewellery Council) with a code of conduct addressing responsible sourcing
(c) Company has a general commitment to responsible sourcing and
human rights protection, without reference to specific materials
(d) Company does not have a policy, but its key clients belong to an industry
organization (e.g., EICC, Responsible Jewellery Council) with a code of
conduct addressing responsible sourcing
(e) No evidence of responsible sourcing commitment
(f) No disclosure
• Keyword(s):
controversial materials, smelters, refineries, conflict minerals, RBA, JEITA,
RJC, GeSI, RMI
• General Procedure: Commented [ACJ37]: Pending with Content Team:
- Check the Industry Organization - Members website:
Specific Scoring Guidance for Jewelry issuers and a
o GeSI – Global Enabling Sustainability Initiatives List of Industry Organization
o RBA – Responsible Business Alliance (use to be EICC)
o RMI – Responsible Minerals Initiatives
o JEITA – Japan Electronics and Information Technology
Industries Association
o RJC – Responsible Jewellery Council
- This can be applied to company supplier. Ensure that they are
member of an industry organization.
- Scoring:
o Company's responsible sourcing policy extends to

materials not currently covered by international mandates
(e.g., cobalt, colored gems) – This drop-down option offers
meaningful differentiation among industry leaders. Only
limited number of high-profile companies openly claimed to
extend their policy beyond 3TG.
o Company belongs to an industry organization (e.g., EICC,
Responsible Jewellery Council) with a code of conduct
addressing responsible sourcing – no formal policy but a
member of an industry group list above
• Note: Make sure to check the list of membership in
the company website.
o Company has a general commitment to responsible
sourcing and human rights protection, without reference to
specific materials – if the company disclose that they
adhere and have formal policy or statement that prohibits
sourcing of conflict minerals but the company itself are not
part of industry organization.
• Sample: There were some instances that they are
adhered to follow the RBA policy but not a member
of the industry organization. Hence, this can be
scored as there is a company commitment.
• Note: Most companies in this industry have formal
policy, but the policy must explicitly
“prohibits/avoids/eliminates” the sourcing of
conflict minerals
o Company does not have a policy, but its key clients belong
to an industry organization (e.g., EICC, Responsible
Jewellery Council) with a code of conduct addressing
responsible sourcing – No policy, but key clients belong to
an industry organization.
o No evidence of responsible sourcing commitment – if
company disclose only that they monitor or oversight or
audit but there is no clear target or details on conflict
materials.
o No disclosure
Practices – Policy to address controversial raw materials

Evidence of commitments towards avoiding controversial materials
• Definition: This data point pertains to the evidence of commitments
towards avoiding controversial materials
(a) Publicly stated formal policy
(b) The company is a member of an industry group that has a policy
(c) The company has a general statement of commitment but no formal
policy
(d) None of the above
• Keyword(s):
‘controversial materials’, ‘smelters’, ‘refineries’, ‘conflict minerals’
- Scoring:
o Publicly stated formal policy – must be formal policy or
statement that prohibits sourcing of conflict minerals (most
companies in this industry have formal policy, but the policy
must explicitly “prohibits/avoids/eliminates” the sourcing
of conflict minerals.
o The company is a member of an industry group that has a
policy – no formal policy but a member of an industry group.
• GeSI – Global Enabling Sustainability Initiatives
• RBA – Responsible Business Alliance (use to be
EICC)
• RMI – Responsible Minerals Initiatives
• JEITA – Japan Electronics and Information
Technology Industries Association
• RJC – Responsible Jewellery Council
o The company has a general statement of commitment but
no formal policy – acknowledgement of the risk and issue,
but no formal statement or member of an industry group.
o None of the above – no evidence
Practices – Future targets regarding raw materials sourcing

Targets towards ensuring compliance with controversial materials
sourcing policy
• Definition: This data point pertains to the targets towards ensuring
compliance with controversial materials sourcing policy.
(a) The company has clear measurable targets or all products are already
certified or traced
(b) General target of continuous improvement (e.g. development of
tracking programs)
(c) No targets
• Keyword(s):
controversial materials, smelters, refineries, conflict minerals, targets,
tracking, conflict free, audit, track
- This should be a quantitative or clearer indication of the goal or
targets to score this as highest score. If there is no disclosure that
could back up the targets or certified product then scored as
General target.
- Scoring:
o The company has clear measurable targets or all products
are already certified or traced – score if the company
disclose the following:
• conducting on-site visits and audits on conflict
minerals issues in the following year; or
• tracking exercise year on year targets until its 100%
conflict free.
• requirement for a portion/all of smelters to
participate audit program within a specific timeline
and real business consequences if smelters fail to
do so; including emerging new conflict minerals in
sourcing policies (e.g. cobalt, colored gems)
o General target of continuous improvement – if company
only disclose that they will reduce conflict materials or when
the company only mention all the product are certified or
traced but if don’t disclose an information about what kind
of targets they have or how they improve or manage their
supplier for the conflict materials.
Practices – Percentage of products externally certified by

agencies
Extent of material certification by external agencies
- Do not score this data points as it is available under Percentage of
products traceable origin of raw materials. Hence, should be scored
as No Value.
- Note: Change the published data to No Value.
Practices – Collaboration with suppliers to address impacts of

raw materials
Extent of efforts to ensure compliance with controversial materials
sourcing policy
• Definition: This data point pertains if the company carry out initiatives to
ensure compliance with controversial sourcing policy or collaborate with
stakeholders to promote supply chain transparency and accountability.
(a) All suppliers audited or all materials certified/traced
(b) Concrete initiatives underway
(c) Member of Extractive Working Group of EICC/GeSI
(d) Minor Initiatives
(e) General Statement
(f) None
• Keyword(s):
Conflict-free, RMAP, CFSP, smelters, refineries, EICC, suppliers, audits,
supplier engagement, education, collaboration, supplier outreach, on-site,
training
- Scoring:
o All suppliers audited or all materials certified/traced –
100% of smelters audited by the CFSP/RMAP or in the audit
process
o Concrete initiatives underway – At least 2 or 3 of below are
disclose
• concrete initiatives such as a majority of supplier are
certified (>60% of conflict free certification)
• substantial capacity-building and education/training
for both internal procurement personnel and
suppliers
• on-site visits and audits,
• support of responsible in-region sourcing
• high-level transparency: at least info on name,
location, sourced metal and CFSP status for all
smelters identified.
• Recommend or communicate with the suppliers on
some measures to abide certain initiatives
o Member of Extractive Working Group of EICC/GeSI – the

company must be an active member of the Extractive
Working Group to select this option
• no public list of Extractive Working Group members,
companies might state that they are Extractive
Working Group members
• Note: this is not the same as EICC membership,
o Minor Initiatives – some supplier engagement or initiative
to ensure compliance with controversial sourcing policy but
there are no details.
o General statement – general discussion or
acknowledgement of the issue and risk, but no explicit
examples or due diligence efforts.
• Note: This is not likely for US companies.
o None – no evidence of supplier engagement on the issue
Practices – Percentage of products externally certified by

agencies with the most stringent standards
Extent of material certification by external agencies using the most
stringent criteria
• Definition: This data point pertains to the extent of material certification by
external agencies using the most stringent criteria
(a) All Products
(b) More than 60%
(c) Between 30-60%
(d) Up to 30%
(e) None
• Keyword(s):
RMAP, conformant, active, conflict free
- Source: AR, CSR, Company Website and SD Form
- CMRT IS NOT RMAP
- When a company validates its smelter supply chain with RMAP, the
company should include how many of the smelters were verified as
conformant or conflict free vs active smelters on the RMAP third
party audit list (conflict free smelters).
o If there's a vague indication of smelters identified: that the
company has difficulties identifying all suppliers/smelters
or if there remains any active smelters identified in their

supply chain, credit cannot be 100% or All Products.
- This indicator should reflect what % of the smelters and refiners in
their supply chain are already validated as conformant (i.e. conflict
free) by the RMAP.
o Smelters and refiners identified as “Active” should NOT be
counted in. This SHOULD NOT include those that are
participating in the program but haven’t achieved the
conflict-free status yet or companies have only committed
to undergo an audit.
- Scoring:
o Choose the best option that validate the % of smelters
identified.
• If the company / suppliers are participating in RMAP
audit process
• How many suppliers then count the number of
suppliers that company reported verified as
conformant.
o Sample: If the company reported that All smelters are
audited, 50 % active and 50% conformant then we only
scored this as Between 30-60%
- RMAP is the flagship assurance program developed by RMI. Being
a member of RMI does not necessarily mean the company
participated in RMAP.
- Note: Should cover all 4 3TG minerals, not just select minerals.
Practices – Percentage of products traceable origin of raw

materials
Extent of material traceability to place of origin
• Definition: This data point indicates percentage of products with traceable
origin of raw materials.
Traceable origin refers to the location where the ore was mined, to the best
detail possible. At a minimum, the description must include the country,
but the more details the better, e.g. province/state, city, mine site and mine
name.)
(a) All Products
(b) More than 60%
(c) Between 30-60%
(d) Up to 30%
(e) None
• Keyword(s):
origin, traceability, accountability, traceability programs, origin tracing,
chain of custody, List of Countries of Origin of Conflict of Minerals, ITSCI,
Better Mining, origin assessment
- Most of the issuers rarely disclose.
- Scoring:
o Choose the best options that indicates traceable programs
company has in place.
o Look for the Chain of custody or list of country or places
where the company trace the raw materials.
o It is also important that they participate in RMAP audits.
o If they disclose the list of countries but they’re not
participating in RMAP programs, then we don’t give credit.
Risk: Dependency on Raw Material – Estimated % of sales

reliant on material (private label where applicable)
Controversial Materials
• Definition: This data point pertains to the estimated % of sales reliant on
material
• Keyword(s):
‘3TGs’, ‘materials’, ‘conflict metals’
- This will be only updated by the Content Analyst
Performance
Percentage of supply externally certified "conflict free" by a third-party
verification
• Definition: This data point pertains to the percentage of supply externally
certified "conflict free" by a third-party verification scheme
(a) 100% Conflict Free
(b) 75-99% Conflict Free
(c) 50%-74% Conflict Free
(d) 25-49% Conflict Free
(e) <25% Conflict Free
(f) None
(g) Not disclosed
• Keyword(s):
‘Conflict-free’, ‘RMAP’, ‘smelters’, ‘refineries’
- Answer if the company is China A issuer unless the issuer is Non-
China A then we must refer in Non-China A requirements document
for specific guidance.
- Scoring: This is interlinked with Extent of material certification by
external agencies using the most stringent criteria.
Corporate Behavior
This theme evaluates the extent to which companies may face ethics issues such as
fraud, executive misconduct, corruption scandals, money laundering, anti-trust
violations, or tax-related controversies.
Sources:
• Annual Report/10K • Wolfesberg Questionnaire
• ESG/Sustainability/CSR report • Audit Committee/ Risk Committee
• Code of Conduct Charter
• Whistleblower Policy
How to identify if issuer is a China A issuer and a State-Owned Enterprise?

China A: If the China Issuer box is ticked.
SOE: s
- Definition: The State identified in the Country of Classification of the issuer
must match the State owning the shares. Where a shareholding is not
directly held by the State, the intent behind the holding is reviewed. A
holding by a government holding company for strategic investments will
generally result in a state ownership classification, whereas holding by a
pension plan for government employees that is managed by independent
trustees will not.
- Procedure for China A: For cases where governance data on SOE is not
available (e.g., Index Adds), in the company's Annual Report, there should
be a list of shareholders that are (国有) state-owned legal person and (非
国) non-state-owned legal person. For a company to be an SOE, the sum of
all the shares of state-owned entities should go over 10%.
- Disclosures:
o Most companies listed in China A are getting dual-listed in
either Hong Kong (English version Annual Reports/ESGRs are
available on the website of HKEX) or New York stock market
(US: a standalone code of ethics is mandatory). Please cross
check with the company website, normally the Investor
Relations section or Corporate Governance section would
include disclosures regarding ethics policies and a
whistleblower reporting section.
- Source:
o Annual report & ESGR
o Internal control report “内部控制报告”
o Internal audit report “内部审计报告”
o Supervisory committee report “监事会报告”

o Party construction “党建” (on corporate website)
- Keywords:
o Anti-corruption “反腐”
o Integrity “廉洁”
o Compliance “合规”
o Anti-monopoly “反垄断”
o Anti-money laundering “反洗钱”
o Discipline of China’s Communists Party (CPC) “党纪” –
related to anti-corruption/bribery
o Eight disciplines of the central government/CPC “八项规定
” – related to anti-corruption/bribery
Policies & Practices

Audits of ethical standards and anti-corruption practices
- Does the company conduct audits of its ethical standards?
- Does the company conduct audit of its anti-corruption policies?
- Does the company state that it audits ALL operations?
• Definition:
- The review of ethics programs and standards generally means that
the policies and compliance procedures are reviewed for
updates/relevance. It doesn’t mean an audit/monitoring of execution
of such policies
- Audits of ethical standards and analyst should not confuse it with
general/financial audits.
- A mere presence of Audit committee or mention of audit word in ethics
policies should not be considered as evidence of ethical standards
audits.
- The evidence should explicitly indicate that the audits are to ensure
compliance with the ethical standards/anti-corruption policies of the
company.
- There should be evidence that the company (either via committee or
team) monitors and checks its “policies and practices”. Look for how a
company is being audited. Meaning, how does the company check that
they’re doing what their policies say they're supposed to do.
o Example 1: Moody’s Corp - Disclosure – “In some cases,
compliance with the Code and other Company policies will
be monitored by periodic audits, investigations or other
reviews. In connection with any such audits, investigations

or reviews, you are required to cooperate fully, provide
truthful and accurate information, and respond to requests
for certifications.”
o Example 2: Argo – Disclosure - The Audit Committee of the
board monitors compliance with the code, including an
annual review of conflicts of interest.
Does the company conduct audits of its ethical standards?

• Definition: Indicates if the company has initiatives to audit or check their
ethical standards
(a) Yes
(b) No
• Keyword(s):
‘check’, ‘monitor’, ‘audit’, ‘audit committee’
- Disclosures should explicitly state that the scope of the audit is for
ethical standards.
- Check if the company conducts audit on their Code of Conduct/Code
of Ethics/Code of Integrity
- The keywords “audit”, “check” and “monitor “are valid to score this data
point as Yes.
- Do not consider compliance and review as an audit. Unless the
company stated that audit committee reviews/monitors/audits their
ethical standards.
China A
- Yes, if evidence of audits regarding AML/KYC, anti-fraud, anti-insider
trading, anti-competitive, content integrity, etc. as pursuant to the
company’s standalone policy statements or major ethics regulations in
China
Does the company conduct audit of its anti-corruption policies?
anti-corruption policies
(a) Yes
(b) No
• Keyword(s):
‘check’, ‘monitor’, ‘audit’, ‘37001’
- Check if anti-corruption is a part of the Code, and audit or check is being

done for the code. Disclosures should explicitly state that the scope of
the audit is for anti-corruption policies and practices.
- If anti-corruption is a separate policy, there should be evidence the
separate policy is being audited or checked.
- If company is ISO 37001 - Anti-Bribery Management Systems certified.
- The keywords “audit”, “check” and “monitor”” are valid to score this
data point as Yes.
- Do not consider compliance and review as an audit. Unless the
company stated that audit committee reviews/monitors/audits their
anti-corruption policies.
- Sample:
o Case 1: Score “Yes”. Company’s Code of Conduct has
anti-corruption/bribery section and there is a disclosure on
monitoring/checking compliance or audits on the Code of
Conduct.
China A
- Rules: Issuer should be a State-Owned Entity (SOE)
- Source: SASAC of the State Council: Implementation opinions on
deepening the internal audit and supervision work of central enterprises
http://www.sasac.gov.cn/n2588035/n2588320/n2588335/c1566136
8/content.html
Does the company state that it audits ALL operations?

integrity, ethical, anti-corruption, anti-money laundering, and anti-bribery
practices across all its operations.
(a) Yes
(b) No
• Keyword(s):
‘check’, ‘monitor’, ‘audit’, ‘37001’
- Merely followed by all employees does not equate to auditing of all
operations. It should be clearly stated that all operations/
sites/subsidiaries are being audited on ethical/anti-corruption
standards.
- The keywords “audit”, “check” and “monitor “are valid to score this data
point as Yes.
- The term “Risk Areas” does not necessarily refer to the company's
operations or work sites. It refers to aspects of the company's business
which may be exposed to risks (e.g., supply chain, employees,
government dealings, etc.). This data point looks for ethics compliance
or anti-corruption audits done on all the company's worksites hence,
‘Risk Areas’ cannot be considered.
- Sample:
o Case 1: Score “No”. Company is a subsidiary of parent
company that conducts audit on their ethical standards for
all their operations.
• The evidence will not be valid to the subsidiary if the
if the subsidiary’s Code of Conduct does not
mention audits on ethical standards.
• The subsidiary can inherit policies from the parent,
but we do not assume that programs (e.g., audit) will
be inherited by the subsidiary.
China A
- Rare for Chinese issuers, only scoring ‘yes’ if company clearly states
the scope of audits (i.e., all subsidiaries, associates, and Joint
ventures), and the frequency of audits (i.e., every two or three years).
- Note: In China market, the Big data and AI technique could use for
ethics audit (i.e., AML), in this case there should be a clear review and
escalation process and reporting line for any cases detected by AI
system.
Executive body responsible for managing business ethics and corruption

issues
• Definition: Refers to highest authority or executive body responsible for
managing business ethics and corruption issues.
(a) Board-level committee
(b) C-suite or Executive committee
(c) Special task force or risk officer
(d) Corporate Social Responsibility/ Sustainability team
(e) Minimum practices expected based on domestic industry norms
(f) No evidence
• Keyword(s):
'committee', 'compliance officer', 'reporting', ‘corruption’, ‘ethics’, ‘charter’,
‘term of reference’, ‘audit’
- Clear evidence in the company disclosure documents that states that

the committee’s scope (board/executive/taskforce or risk officer)
covers or includes “business ethics” OR “corruption” issues. If no
evidence exists, a more conservative selection must be picked.
- C-suite/Executive committee/Board-level committee should only be
given when there is clear evidence of their involvement in managing
business ethics related activities or being directly responsible for
organizational compliance with the policies (not just based on a mere
mention of board members or executive officers in the code of conduct
or other policy documents).
- Scoring
o Board-level committee - A committee involving the board of
directors. For example, there is a compliance committee
comprising of Board members. It should be clearly mentioned
that the compliance committee is involved in oversight of
business ethics or anti-corruption issues. Otherwise, do not
score. Same for other dropdown options.
o C-suite or Executive committee - A committee involving
executives from the C-suite (e.g., Chief Compliance monitoring
business ethics and corruption issues).
o Special task force or risk officer – A compliance team/ risk
officer monitors business ethics and corruption issues.
o Corporate Social Responsibility / Sustainability Team - A
Sustainability team is responsible for managing business
ethics and corruption issues.
norms – Only use where there is market specific guidance
China A
- Default Scoring: C-suite or Executive committee
- Source: Provisions on honest work of leading personnel of state-owned
enterprises Ninth article http://www.gov.cn/jrzg/2009-
07/13/content_1363689.htm
Scope of employee training on ethical standards

• Definition: Indicates the scope of employee training on anti-corruption and
business ethics standards.
(a) Programs covering all employees (including part-time) and contractors
(b) Programs covering all permanent employees (excluding part-time and

contractors)
(c) Programs covering all security providers
(d) General statements on employee training on ethical standards
(e) No evidence
• Keyword(s):
'training', 'integrity training', 'ethical practices', 'educate', ‘anti-corruption’,
‘corruption’
- This data point has duplicate tagged as Copy, Lite, China A. Make sure
that answers in 2 fields are the same.
- Scoring
o Programs covering all employees (including part-time) and
contractors -
• All the company's full-time employees, including part-time
and contractors, participate in its training on ethical
standards.
• May be given even if the company intends to train all
employees but mentions that a small percentage of
employee could not take the training in particular year (e.g.,
97% of our employees completed the mandatory training on
business ethics.). Commented [LRA38]: To be confirmed first with the
o Programs covering all permanent employees (excluding part- Content Team.
time and contractors) - All the company's full-time employees
are eligible to participate in its training on ethical standards
o Programs covering all security providers - All the company's
security providers participate in its training on ethical standards
o General statements on employee training on ethical standards
• Company disclosed business ethic training without
giving details about the scope of employees
covered.
• If the company let the employees to read and sign
the ethical standards every year, then this option can
be chosen.
China A
- Default Scoring: General statements on employee training on ethical
standards

enterprises 17th article http://www.gov.cn/jrzg/2009-
- Scoring:
o Programs covering all employees (including part-time) and
contractors - RARE for CN issuers, select this only if the
disclosed number of employees trained is in line with the
number of total workforces and explicitly state this includes
contractors.
o Programs covering all permanent employees (excluding part-
time and contractors - RARE CN issuers, select this only if the
disclosed number of employees trained is in line with the
number of total workforces.
o Programs covering all security providers - O&G and mining
companies, human rights Commented [LRA39]: @Atilano, Cristine Joyce to
confirm with CN experts
Child data points of Scope of employee training on ethical standards
- Full-time/permanent employees
- Temporary/part-time employees
- Business partners/vendors/suppliers/contractors
- Contract security providers
- Evidence of training but scope is not clear
- No evidence
• Definition: Identifies the type of employees included on anti-corruption and
business ethics standards.
• Keyword(s):
'training', 'integrity training', 'ethical practices', 'educate'
N/A – Checkbox
General Procedure:
- Scoring Guidance:
o Full-time/permanent - Tick if training on ethical standards
covers permanent or full-time employees
o Temporary/part-time employees - Tick if training on ethical
standards covers temporary or part-time employees
o Business partners/vendors/suppliers/contractors - Tick if
training on ethical standards covers business partners, vendors
or suppliers, or contractors
oEvidence of training but scope is not clear - Tick if there is

disclosure on training on ethical standards, but covered
employee groups are not identified
o No evidence - Tick if there is no evidence of training on ethical
standards for any of the above employee groups.
- Scoring Guidance for Parent Data point - Specific Industry Rules
supersede below general guidance.
o Select ‘Programs covering all employees (including part-time)
and contractors’ if Child data points ‘Full-time/permanent’,
‘Temporary/part-time employees’ and ’Business
partners/vendors/suppliers/contractors’ are scored. Note:
Include ‘Contract security providers’ for relevant industries
o Select ‘Programs covering all permanent employees (excluding
part-time and contractors)’ if only Child data point ‘Full-
time/permanent’, is scored.
o Select ‘Programs covering security providers’ if only Child data
point ‘contract security providers’ is scored. Note: Applicable
Only to relevant industries
o Select ‘General statements on employee training on ethical
standards’ if only Child data point ‘Evidence of training but
scope is not clear’, is scored.
o Select ‘No evidence’ if only Child data point ‘No evidence’, is
scored.
Company's bribery and anti-corruption policy

• Definition: Indicates if the company has a policy on bribery and anti-
corruption in place and the scope of that policy.
(a) Detailed formal policy on bribery and anti-corruption
(b) General statements of commitment to address bribery and corruption
issues
(d) No evidence
• Keyword(s):
'bribery', 'anti-corruption', 'gifts', 'ethics'
- The company should have own formal policy for bribery and anti-
corruption and not only following government policy (e.g., Foreign
Corrupt Practices Act that applies to all organizations of USA).
Scoring:
o Detailed formal policy on bribery and anti-corruption
Company has adopted a standalone policy on bribery and

▪
anti-corruption or has a summary on addressing bribery and
anti - corruption issues.
▪ Generally, we can consider a policy to be detailed and
formal if it includes expectations of employees, monitoring,
training requirements and associated corrective actions
breaches in expected behavior.
▪ Commonly selected if the company has separate document
that provides full information of their bribery and corruption
policies.
o General statements of commitment to address bribery and
corruption issues
▪ Company addresses bribery and corruption issues. Mere
claims of avoiding unethical behavior and bribery etc.
without clear set of instructions for employees regarding
expected behavior/approach to gifts/corruption/bribery.
This can be generally found in the Code of Conduct, Code of
Ethics, or CSR.
▪ If you find evidence that there is policy available, but it is not
accessible to you, still credit the company with this option.
▪ If the company has a formal policy that is in reference or
compliance with regulations like FCPA, this option can be
chosen.
norms – Only use where there is market specific guidance
• Interlinked Data Point(s) Guideline
- If UN Global Compact signatory under Corruption & Instability is “Yes”,
this data point should not be “No evidence”.

Industry Guideline
- EU and US – we can give “General statements of commitment to
address bribery and corruption issues” even if there is no direct
evidence available
o Country of domicile 'US', 'AU', 'AT', 'BE', 'DK', 'FI', 'FR', 'DE', 'IE',
'IT', 'NL', 'NO', 'PT', 'ES', 'SE', 'CH', and 'GB'.
China A
- Default Scoring: General statements of commitment to address bribery
and corruption issues

enterprises Ninth article http://www.gov.cn/jrzg/2009-
07/13/content_1363689.ht
- ‘Detailed formal policy on bribery and anti-corruption’

o China A/Hong Kong market: RARE for companies listed in
these two markets only; but some issuers may disclose
extracted a summary of policy details in the CSR/ESGRs,
credits may be given if terms related to bribery/anti-
corruption clearly stated.
o US market: mandatory to disclose a standalone Code of
Ethics through SEC filings and/or company websites (for
dual-listed issuers) Commented [LRA40]: @Atilano, Cristine Joyce, this is
- Keywords: part of China A procedure. This happens for dual listed
issuers.
o anti-bribery/anti-corruption “反腐” or “反贪”
o clean governance/integrity “廉洁” or “廉政”
o (CPC) Party ethics “党风”
o compliance “合规”
Provision of whistleblower protection (Revised Methodology – 06/22) Commented [LRA41]: @Atilano, Cristine Joyce check
• Definition: Indicates whether the company has disclosed a whistleblower with CN experts the new procedure.
policy that provides whistleblowers with protection from retaliation.

(a) Policy provides whistleblowers with protection from retaliation
(b) No evidence
• Keyword(s):
'whistleblower', 'legal protection', 'retaliation', 'anonymous'
whistleblowing “举报”
- Scoring
o Policy provides whistleblowers with protection from
retaliation
• The policy states that whistleblowers will be
protected from retaliation.
o No evidence - Either a) the policy does not indicate that
whistleblowers are protected from retaliation; or b) the
company has not disclosed the adoption of, or any details
regarding, a whistleblower policy.
- Definition of retaliation: Retaliation includes any disadvantageous
actions/inactions toward the whistleblower without cause.
- What has changed?

o There is no need to look for a toll-free line/24-hour service
for reporting violations.
o Anonymity in reporting is removed from the criteria and
keyword list
o The term “Legal” protection is eliminated from the criteria
and keyword list. We should only look for protection from
retaliation.
- Other nuances:
o There should be explicit mention that whistleblowers are
protected from retaliation. Generic statements that the
company does not tolerate unfair treatment to
whistleblowers, without mention of any form of protection,
should not be given credit.
o Policy can refer to a formal whistleblower policy, code of
ethics or code of conduct, anti-corruption policy, anti- or
non-retaliation policy, or any written statement on
whistleblower protection from retaliation on the
annual/CSR reports or website.

JP Companies
- Sub-Industry: All
- Default Scoring if a company has more than 300 employees: Policy
provides whistleblowers with protection from retaliation
FR Companies
- Sub-Industry: All
- Default Scoring if a company has more than 50 employees: Policy
provides whistleblowers with protection from retaliation
Provision of whistleblower protection (Legacy Methodology)

• Definition: Indicates whether the company's business ethics policy
includes a whistleblower protection provision.
(a) Formal anonymous whistleblower system with legal protection
(b) Whistleblower protection with no details on system or legal protection
(d) No evidence
• Keyword(s):
'whistleblower', 'legal protection', 'retaliation', 'anonymous'
- Scoring
o Formal anonymous whistleblower system with legal protection
• Addition to setting-up a whistleblower channel the
company also provides means of protecting the
whistleblower against retaliation. If the company
has a categorically stated of providing legal
Protection for the Whistleblower.
• The highest credit should be given if there is
evidence of a non-retaliation policy or protection
against retaliatory action - the latter should clearly
state what the company will do to those who violate
whistleblower policies (for example, termination or
disciplinary action)
o Whistleblower protection with no details on system or legal
protection - if there are brief or general statement related to
whistleblower protection without indicating legal protection
• This includes but not limited to the following
examples:
▪ Toll-free line/24-hour service to report
violations with strong indication that
whistleblowers will be protected, often by
involvement of independent parties.
▪ If the company supports anonymous
reporting and has a system and program in
place to support and protect whistleblower.
▪ There is an evidence of whistle blower policy
in place.

JP Companies
- Sub-Industry: All
- Default Scoring if a company has more than 300 employees:
Whistleblower protection with no details on system or legal
protection
Scope of anti-corruption policy for suppliers

• Definition: Indicates the scope of the bribery and anti-corruption policy in
place for suppliers.
(a) All suppliers are required to have anti-corruption policies and programs
to verify compliance
(b) All suppliers are required to have anti-corruption policies
(c) Policy covers selected suppliers
(d) No evidence
• Keyword(s):
'suppliers', 'vendors', 'anti-corruption'
- Scoring:
o All suppliers are required to have anti-corruption policies and
programs to verify compliance - Programs to verify compliance
should include audits of suppliers or requiring suppliers to
conduct audits on anti-corruption. Training of suppliers is not
enough for highest credit.
o All suppliers are required to have anti-corruption policies - All
suppliers must have their own anti-corruption policies, or they
comply with the organization’s Supplier Code of conduct. This
option must cover 2 points:
▪ Here company will specify that the suppliers must have their
own bribery and anti-corruption policy OR they comply with
the organization’s Supplier Code of conduct; and
▪ The organization will conduct assessments at supplier
locations or there can be self-assessment and report is
submitted to the organization
o Policy covers selected suppliers - The company has its own
policy/Code of Conduct that covers selected suppliers/tier one
suppliers/critical suppliers etc. If scope of policy is not
mentioned, this option can still be selected.
Industry Guideline
China A
- Scoring
o All suppliers are required to have anti-corruption policies
and programs to verify compliance - Check company
website procurement section, only if inspection/audit
reports submitted to the issuer
o Policy covers selected suppliers - i.e., “Integrity

letter/commitment”
Policies related to Anti-Money Laundering (AML) and Know Your

Customer (KYC)
• Definition: Refers to the extent of the of the company’s Anti-Money
Laundering (AML) and Know Your Customer (KYC) policies. This applies to
financial instability companies.
(a) Policy and implementation strategy articulated
(b) Evidence of policy but no disclosure of implementation
(c) Not disclosed
• Keyword(s):
'anti-money laundering', 'laundering' 'anti-terrorism', 'know your customer'
- Answer if the company is categorized as Casino & Gaming or
Consumer Finance and/or if company is assessed on Access to
Finance key issue
- Full credit should be given if the company in addition to having an anti-
money laundering policy provides details of mechanism/measures
undertaken to execute it.
o Examples of these mechanisms include but are not limited
to: Audits of AML/KYC policy, Sanction programs or
screening, suspicious transaction reporting, customer due
diligence, transaction monitoring, and financial crime
compliance questionnaire. Trainings on AML/KYC are not
enough to merit highest credit.
China A
- Sub-Industry: Diversified Banks, Regional Banks
- Default Scoring: Evidence of policy but no disclosure of
implementation
- Policy and implementation strategy articulated – Common in IT and/or

big data-powered
Government Ownership and Involvement Table

Add a row even if there is no evidence found.

Percentage of Government Ownership
• Definition: Indicates the proportion of the company that is government
owned
N/A - Numeric Input Value – in percentage
• Keyword(s):
'government', 'state-owned', 'number of shares'
- The State identified in the Country of Classification of the issuer must
match the State owning the shares. Where a shareholding is not directly
held by the State, the intent behind the holding is reviewed.
- A holding by a government holding company for strategic investments
will generally result in a state ownership classification, whereas holding
by a pension plan for government employees that is managed by
independent trustees will not.
- We check the Corporate Governance form and the data disclosed in a
Company’s AR (as reported) using these keywords:
o English: “Government”, “state-owned”, “ownership”
o Korea: 정부 소유권 (government ownership), 주주
(shareholders), 대주주 (major shareholders), 주식 소유현황
(stock ownership status)
oJapan: 大株主 (major shareholder), 株主 (shareholder), 株
(stock/share)
o China: 国有 (state-owned legal person)
- National Pension Services (NPS)’s stake should not be counted as
government ownership.
Estimated value of political donations / lobbying expenditure

• Definition: Provides the estimated value of political donations or lobbying
expenditures by the company
• Keyword(s):
‘politics’, ‘political’, ‘donation’, ‘contribution’, ‘lobbying’
- Provide the total political donations / lobbying expenditure expressed
in USD
Estimated percentage of revenues from government contracts

• Definition: Provides the estimated percentage of company revenue derived
from government contracts
N/A - Numeric Input Value – in percentage
• Keyword(s):
‘government contracts’, ‘government concessions’
- Provide the reported or calculated percentage of company revue from
government contracts
Corruption & Instability

Companies are evaluated on the extent of their operations in regions with a high
degree of corruption, political instability or violence, the strength of their anti-
corruption efforts and their commitments to protect human rights.
Note: Only update metrics data point.
SDG
UN Global Compact signatory
• Definition: This data point shows whether or not the company is a UNGC
signatory
a) Yes
b) No evidence
• Keyword(s):
UNGC, United Nations Global Compact
- Check on the UNGC website if the company is currently a signatory
o Check Global Compact Status. Only consider those marked
as Active / Non-Communicating.
List of commitments to ethics and anti-corruption mandates

• Definition: This refers to whether the company adheres to certain
ethics and anti-corruption mandates/policies/standards
N/A = this is a free text
• Keyword(s):
UNGC, United Nations Global Compact, Partnering Against Corruption
Initiative, PACI, Extractive Industries Transparency Initiative, EITI, ISO
37001, ISO-37001, ISO37001, UK Bribery Act 2010, Convention on the
protection of the EC financial interests, The Criminal Law Convention on
Corruption, Foreign Corrupt Practices Act, FCPA, UN Convention against
corruption (UNCAC, 2003), Transparency International's Business
Principles for Countering Bribery, The Twenty Guiding Principles for the
Fight against Corruption
- List down the mandates that the company follows on ethics and anti-
corruption; standards provided in the keywords above
Scope of supplier monitoring programs to verify anti-corruption policy

compliance
• Definition: This data point informs stakeholders about the percentage of
suppliers selected or contracted subject to due diligence processes for
impacts on society. This refers to the scope of suppliers where ethics
oversight activities (due diligence, audits, verification) are being
implemented on. Due diligence should be initiated as early as possible in
the development of a new relationship with a supplier. Significant potential
negative impacts on society may be prevented or mitigated at the stage of
structuring contracts or other agreements.
(a) Monitors all critical suppliers
(b) Monitors selected suppliers
(c) General statements on supplier business ethics due diligence
(d) No evidence
• Keyword(s):
Supplier, monitor, due diligence, anti-corruption, anti-bribery
- Check if there is mention of the scope of suppliers where ethics
oversight activities (due diligence, audits, verification) are being
implemented on
- Supplier code of conduct can be a reference document. Specifically,
there should be a mention of anti-corruption or preventing corruption in
the code of conduct.
- The "Scope of anti-corruption policy for suppliers" data point in
Corporate Behavior just covers the extent of suppliers covered by a
company's anti-corruption policy. This data point refers to the scope of
suppliers where ethics oversight activities as mentioned (due diligence,
audits, verification) are being implemented on.
- Scoring:
o Monitors all critical suppliers - Look for monitoring process
of ethical standards and anti-corruption policy for suppliers.
The scope includes all the suppliers or all “high-risk” or
critical suppliers and there are disclosures on the ethics
oversight/monitoring activities mentioned.
o Monitors selected suppliers - Look for monitoring process
of ethical standards and anti-corruption policy for suppliers.
The scope includes selected suppliers or scope is not
determinable but there are disclosures on the ethics
oversight/monitoring activities mentioned.
o General statements on supplier business ethics due

diligence - No specific details on the monitoring process for
the suppliers, but there are some general statements made
(mentions preventing corruption in supply chain, but the
type of monitoring activities is NOT disclosed)
o No evidence - If none of the above-mentioned disclosures
are provided by the company, we give it the least credit i.e.,
no evidence.
List of commitments to external mandates to protect human rights

• Definition: This refers to whether the company adheres to certain human
right mandates/policies/standards
N/A - Long Text
• Keyword(s):
UK Modern Slavery Act 2015, Universal Declaration of Human Rights
(UDHR), Responsible Business Alliance (RBA), International Labour
Organization (ILO), International Bill of Human Rights, UN Guiding
Principles on Business and Human Rights, The Tripartite Alliance for Fair &
Progressive Employment Practices (TAFEP) Tripartite Standards
- List down the mandates that the company follows on human rights;
standards provided in the keywords above
ESG Metrics Commented [LRA42]: Industry rule to be confirmed.
Company's monitoring process to measure effectiveness of its human

rights policy
• Definition: This data point provides information on company's monitoring
process to measure effectiveness of its human rights policy
(a) Company has defined a structured monitoring process and sets targets,
and reports achievement against targets
(b) Company has defined a structured monitoring process and sets targets
but does not report on achievement against targets
(c) General statements on monitoring the human rights policy performance
exists
(e) No evidence
• Keyword(s):
Human rights, human rights monitoring, audits of human rights policies
- Scoring:
o Company has defined a structured monitoring process and
sets targets, and reports achievement against targets –
• The company has a process of monitoring their
human rights policy, sets goals, and discloses their
achievements on the set targets/goals.
• Structured monitoring refers to audits of operations
on human rights policies. For this to be considered
"structured", there should be set indicators that the
company measures and tracks. Highest credit goes
to having targets on said indicators. Mere mention
of human rights audits or human rights monitoring
should be general statement only. Reference to
human rights monitoring standards of the United
Nations Office of the High Commissioner for Human
Rights without disclosing indicators can also be
considered as general statement.
o Company has defined a structured monitoring process and
sets targets but does not report on achievement against
targets - The company has a process to monitor their
human rights policy and sets goals but does not mention
the achievements on the set targets/goals.
o General statements on monitoring the human rights policy
performance exists - Minimal disclosure on human rights.
Or mere mention of human rights audits or human rights
monitoring; Reference to human rights monitoring
standards of the United Nations Office of the High
Commissioner for Human Rights without disclosing
indicators
norms - Currently not using this option; please refrain from
using.
o No evidence - No information found
Industry Guidelines
- Sector: Health Care
o Check if the company is monitoring its clinical trials
Memberships in external business ethics and/ or anti-corruption

initiatives with high standards
• Definition: This data point provides information on company's
memberships in external business ethics and/or anti-corruption initiatives
with high standards
(a) Membership in internationally recognized initiatives with high
standards
(b) Membership in industry/ region-specific initiatives
(c) Business ethics and corruption policy is aligned with external standards
(e) No evidence
• Keyword(s):
UNGC, United Nations Global Compact, Partnering Against Corruption
Initiative, PACI, Extractive Industries Transparency Initiative, EITI, ISO
37001, ISO-37001, ISO37001, UK Bribery Act 2010, Convention on the
protection of the EC financial interests, The Criminal Law Convention on
Corruption, Foreign Corrupt Practices Act, FCPA, UN Convention against
corruption (UNCAC, 2003), Transparency International's Business
Principles for Countering Bribery, The Twenty Guiding Principles for the
Fight against Corruption
- Scoring:
o Membership in internationally recognized initiatives with
high standards - If the company is member, participant, or
signatory to multiple external standards like UNGC,
Partnering Against Corruption Initiative (PACI), Extractive
Industries Transparency Initiative (EITI), ISO 37001,
Transparency Intl Principles for Countering Bribery, etc.
Please exercise judgment on whether the initiative to which
a company is a member of is a global initiative.
o Membership in industry/ region-specific initiatives - If the
company is member, participant, or signatory of a more
region-specific, or industry-specific standard or initiatives.
This is also applicable for a company that is a signatory or
participant of UNGC, but only for a specific market or
chapter, and not included in the UNGC global website list.
o Business ethics and corruption policy is aligned with
external standards - If the company is neither a member,
participant, nor signatory of the above standards but
mentions that they follow or aligns with principles of any of

the above standards.
norms - Currently not using this option; please refrain from
using
o No evidence - No information found
Industry Guidelines
- Sector: Health Care
- Scoring:
o Membership in internationally recognized initiatives with
high standards - if company is a signatory to UNGC
o Membership in industry/ region-specific initiatives - if
company is a signatory to
Phrma/EFPIA/IFPMA/Medtech/JPMA
o Business ethics and corruption policy is aligned with
external standards - if company is aligned to external
standards like Phrma, IFPMA, EFPIA, Medtech, JPMA
Electronic Waste
This issue evaluates the extent to which companies that produce or sell electronic
products may face regulatory risks associated with recycling or disposal of end-of-
life electronic products. Scores are based on exposure to evolving e-waste
regulations; targets and programs to collect and recycle electronic waste; and
controversies.
Take back Programs vs Recycling Programs

Take Back Programs refer to initiatives wherein a company re-collect used products
from its consumers/customers and reintroduce them into the manufacturing
process. Some companies would also refer to this as Recycling program, but it must
be clear that the electronic products being recycled are end-of-life collected from
consumers.
It is important to remember in this Key Issues that collection and recycling of the e-
waste should be own manufacturing products that sold with the consumer and when
the company have a take back program or its own efforts to recycle consumer end of
life products.
Recycling efforts like packing materials or company efforts to recycle their own
operation electronic waste is not applicable for this Key Issues. This should be focus
on Take Back program for Consumers.
Practices
Explicit ban of exportation of e-waste to non-OECD countries (in accordance with
the Basel Ban Amendment to the Basel Convention)
• Definition: This data point pertains to the explicit ban of exportation of e-
waste to non-OECD countries
(a) Yes
(b) No
(c) Not disclosed
• Keyword(s):
Basel, Basel Ban, Basel Convention, electronic waste, e-waste, collect,
recycling, OECD
- If the company is a signatory/ membership to Basel Ban
Amendment to the Basel Convention or abides by this convention.
Means available for returning end-of-life electronics to the

company
E-waste take-back programs include drop-off (at a store or designated
pick-up locations)
• Definition: This data point checks if the company has an e-waste take-back
programs which include a drop-off option
(a) Yes
(b) No
(c) Not disclosed
• Keyword(s):
electronic waste, take-back, drop-off, collect, recycle, take back
- If the company provide a service for the customer that can drop off
the used product at the store or some designate location.
E-waste take-back programs include mail-in of end-of-life products

programs which include a mail-in option
(a) Yes
(b) No
(c) Not disclosed
• Keyword(s):
End-of-life products, electronic waste, take-back, mail-in, collect, recycle,
take back
- The products that are indicating that the product is in the end of its
useful life which are been collected.
E-waste take-back programs include pick-up of end-of-life products

programs which include a pick-up option
(a) Yes
(b) No
(c) Not disclosed
• Keyword(s):
End-of-life products, electronic waste, take-back, pick-up, collect, recycle,

take back
- If the company provides the service for the products to be pick up.
- This should be detailed information of service
Take-back exists but no details given

programs, but no details were given regarding the products.
(a) Yes
(b) No
(c) Not disclosed
• Keyword(s):
electronic waste, take-back, collect, recycle, take back
• General Procedure: Commented [ACJ43]: Pending with Data Ops:
- This data point should only be at No Value if any of the following
Create Stop Pub
data points are Yes; otherwise, it will have to be scored No or Not
Disclosed depending on the company disclosure
o E-waste take-back programs include drop-off (at a store or
designated pick-up locations)
o E-waste take-back programs include mail-in of end-of-life
products
o E-waste take-back programs include pick-up of end-of-life
products
- If the score provided in all the 3 data points above is No/Not
disclosed, then this cannot be No Value, hence, should be scored
No/Not Disclosed depending on disclosure
o No = company clearly stated that the company does NOT
have the program stated in the data point
o Not disclosed = no evidence is found
• Guidelines for Specific Industry / Market Commented [ACJ44]: Pending with Market Leads:
China A
- Industry: Household Appliances and Consumer Electronics Default scoring for other Markets
- Specific Procedure: If the company’s core business involves in

manufacturing of TV, air conditioner, refrigerator or washing machine
AND no e-waste take-back programs can be found (drop-off, pick-up or
mail-in)
- Source: According to Circular Economy Promotion Law of the PRC
(Chapter 2, Article 15), consumers shall hand over the discarded
products or packages to the producers or sellers or the third parties

companies entrusted for recycling.
Facilities that handle recycling of collected electronics

Availability of own e-waste recycling facilities
• Definition: This data point checks if the company has its recycling facility.
(a) Yes - and does not use third parties
(b) Yes - but also uses third parties
(c) No or no recycling program
• Keyword(s):
electronic waste, recycling, recycling facilities, collect, recycle, take back,
take-back
- Check if the company recycling their own products procured from
the customer.
Participation in industry networks that support or operate recycling
facilities
• Definition: This data point checks if the company participates in industry
networks that support or operate recycling facilities
(a) Yes
(b) No
(c) Not disclosed
• Keyword(s):
electronic waste, recycling, recycling facilities, collect, recycle, WEEE,
Waste Electrical and Electronic Equipment Directive, take back, take-back
- Check if the company participate in industry networks wherein,
they support or operate recycling facilities.
- US Companies have a mandated service of electrical or electronic
equipment guideline. Sometimes the company disclose that they
have recycling measure with industry networks or recycling
agencies.
Designated vendors for e-waste recycling
• Definition: This data point checks if the company has recycling partners
and third-party vendors where they can recycle their products.
(a) Yes - and there is auditing either by the company or a trusted
independent auditor (e.g., the e-Steward organization)
(b) Yes - but no audits are reported

(c) No or no recycling program
• Keyword(s):
Third party, vendors, electronic waste, recycling, recycling facilities, collect,
recycle, audits, auditing, take back, take-back
- Check if the company has a recycling partner or a third-party
vendor where they can recycle their products.
- If the company are audited by the company or trusted independent
auditor, then we could give the highest credit. This should be
explicit mention that it was audited.
China A Commented [ACJ45]: Pending with Market Leads:
- Sub Industry: Household Appliances & Consumer Electronics and
Communications Equipment; Electronic Equipment & Instruments; Default scoring for other Markets
Electronic Components
- Default Scoring: Yes - but no audits are reported
- Source: Notice on strengthening environmental management of
waste electrical and electronic equipment (关于加强废弃电子电气设
备环境管理的公告 ):
http://www.mee.gov.cn/gkml/zj/wj/200910/t20091022_172222.ht
m
The waste electrical and electronic products Recovery Management
Ordinance (废弃电器电子产品回收处理管理条例):
Law of the People's Republic of China on the Prevention and Control
of Environment Pollution Caused by Solid Wastes (2020 Revision)
http://www.moj.gov.cn/Department/content/2020-
05/06/592_3248103.html
General statement on recycling e-waste

• Definition: This data point refers to the company's general statement on
recycling e-waste
(a) Yes
(b) No
(c) Not disclosed
• Keyword(s):
take-back
- This will be score if the company gave a general statement on
recycling e-waste
- Can be scored as No Value if the three data points above (under Commented [ACJ46]: Pending with Data Ops:
Facilities that handle recycling) are scored as Yes.
Create Stop Pub
Collection of e-Waste
Scope of the recycling program, by product type
• Definition: This data point refers to the scope of the recycling programs of
a company - by product type
(a) All products and brands are eligible for collection and recycling
(including those not made by the company)
(b) All proprietary products are eligible for collection and recycling
(c) Only select proprietary products are accepted for collection and
recycling
(d) The company provides anecdotal evidence of select products that are
collected and/or recycled
(e) The company has a general statement on product collection and
recycling
(f) No program details disclosed
• Keyword(s):
take-back
- The company disclose the details of the scope of its product types
which are accepted in the collection and recycling programs.
China A Commented [ACJ47]: Pending with Market Lead:
- List of Companies covered for the Default Scoring
Default scoring for other Markets
Coverage as of
Issuers IID
June 1 2022 Commented [ACJ48]: This will be updated time to
Haier Smart Home Co., Ltd. IID000000002126711 Yes time
Gree Electric Appliances, Inc. of Zhuhai IID000000002168285 Yes Commented [LRA49R48]: Include in Appendix
TCL Technology Group Corporation IID000000002130598 Yes
Sichuan Changhong Electric Co., Ltd. IID000000002143231 No
Midea Group Co., Ltd. IID000000002280968 No
HISENSE HOME APPLIANCES GROUP CO., LTD. IID000000002169407 No
- Default Scoring: The company provides anecdotal evidence of
select products that are collected and/or recycled
- Source: Recycling Target Responsibility System Actions in 2022
- Additional Guidelines: if the company has better disclosure on its

recycling program, kindly ignore the baseline selection
Scope of the recycling program, by location
• Definition: This data point refers to the scope of the recycling programs of
a company - by location
(a) Product collection and recycling is uniform across all geographic
segments where the company operates
(b) Recycling available in multiple locations (but not all locations) including
countries not covered by regulatory requirements
(c) Only in markets that regulate collection and recycling
(d) The company has a general statement on product collection and
recycling
(e) No program details disclosed
• Keyword(s):
take-back
- The companies disclose the scope of its location where the
products can be collected and recycle.
- Sometimes the company mention that the e-waste programs are a Commented [ACJ50]: This procedure can be used
line with multiple geographic or markets then we could give a while profiling.
credits for this datapoint.
Pending with Market Lead:
Cost to the consumers of the take-back program
• Definition: This data point refers to the cost to the consumers of the take- Provide a list of markets and geographic that have e-
waste regulation.
back program
(a) Provides credit against a new purchase
(b) Free (shipping included)
(c) For a fee or free except for shipping costs
(d) Company states compliance w/ regulatory requirements or general
statement about recycling program but no details of take-back programs
provided
(e) No take-back program
• Keyword(s):
take-back, shipping, fees, allowance, subsidy
- The company will disclose if cost will be shoulder by the consumer
in take back program.
Financing Environmental Impact

This issue evaluates the extent to which companies may face potential credit or
reputational risks resulting from indirect exposure to the environmental concerns
facing borrowers. Scores are based on estimated environmental risk financing;
environmental due diligence process and “green" financing; and controversial
investments.
Sources:
• Annual Report/10K • EU Taxonomy Reporting
• Audit Committee/ Risk Committee • Green Bon Framewprk
Charter • GRI
• CDP Questionnaire • Investor Presentation
• Company Website • Pillar 3 Disclosure for Loans
• Credit Policy for Industries • SASB
• ESG/Sustainability/CSR report • TCFD
• ESG Policy/Environmental Policy • Pillar 3 Disclosure for Loans
General Procedure:
• Yes - there is evidence found
• No - explicit disclosure that the company has no kinds of product, practice,
program, and/or policy
• No Evidence/ Not Disclosed - if no evidence found
**For published data, there’s no need to change from No to No Evidence/Not
Disclosed. This will be applied moving forward.
Exposure – Exposure to Corporate Financing

Corporate and/or commercial loans as % of total loans
• Definition: Indicates the percentage of corporate and/or commercial loans
of the company.
N/A - Numeric Input Value - in percentage (%)
• Keyword(s):
‘loans’, 'commercial loans', 'corporate loans'
- Computed as total corporate and/or commercial loans divided by total
loans.
- Please exclude all retail loans which are given to individuals from the
Gross Loans including mortgage loans, consumer loans, personal
loans, credit cards and short-term loans (e.g., one year loan or 3-6
months loans). And the remaining shall be corporate/commercial

loans.
- Express this as a % of the Gross Loans at the end of the financial year.
Refer to consolidated balance sheet figures, rather than stand-alone
balance.
- Usually found in banks’ annual report classifying different loans.
- Provide internal notes the items included to compute this data point.
- If there’s no evidence found, leave this blank and do not enter zero.
JP IMI
- Sub-Industry: All
- Default Scoring: >0 if there’s evidence found.
Company underwrites corporate debt and/or equity

• Definition: Indicates if the company has securities underwriting, debt
underwriting, and bond writing, and provides other underwriting services.
(a) Yes
(b) No
(c) Not Disclosed
• Keyword(s):
‘investment banking’, ‘securities underwriting’, ‘equity underwriting’, ‘debt
underwriting’
- Apart from the lending activities, other activities like investment
banking, underwriting securities/equities/debt, securitization, or
capital markets activities.
- Do not consider underwriting related to loans/financing.
JP IMI
- Sub-Industry: All
Company is among the largest 25 underwriters based on aggregate deal

volume (most recent year)
• Definition: Indicates if the company is part of the largest 25 underwriters
based on aggregate deal volume (most recent year).
(a) Yes
(b) No
(c) Not Disclosed

• Keyword(s):
‘loans’, 'commercial loans', 'corporate loans'
- Leadership position in underwriting further aggravates environmental
risks for the banks.
- Scoring
o Yes - if the company is part of the largest 25 underwriters
based on aggregate deal volume (most recent year)
o No - default, if analyzing small-cap company
- Global market issuers to be considered. We can use the list of top
10 based on deal volumes from ft.com for now. Top 10 Global
Banks:
o Goldman Sachs & Co
o Morgan Stanley
o JP Morgan
o Bofa Securities Inc
o Citi
o Jefferies LLC
o Credit Suisse
o CITIC
o Barclays
o UBS
- For issuers that are not included in the above list and have a score
of ‘Yes’, retain the scoring and do not change to ‘No’ or ‘Not
Disclosed’.
Practices – ESG Risk Management Policies

Evidence of policy or systems to manage ESG risks in financing activities
• Definition: Describes whether a company has a policy or systems to
manage ESG risks in financing activities.
(a) Yes
(b) Yes, but no information on scope or depth of policies
(c) No
(d) Not Disclosed
• Keyword(s):
'ESG risk', 'environmental risk', 'Equator Principles', ‘green finance’,
‘responsible finance’, ‘responsible investment’
- This data point highlights whether the institution has a policy in place
that either identifies ESG as a credit risk or outlines management of
ESG risks to credit.
- Do not count efforts to manage environmental risks in operations
Example: ESG risks – reduce their carbon footprint / carbon emission
and energy efficiency
- If answer is ‘Not Disclosed’ or ‘No’ SKIP remaining ESG Risk
Management Policies and Implementation questions.
- Examples: Many banks have systems in place to monitor or manage
environmental or social risks in their lending portfolio. This includes
adoption of the Equator Principles as a form of risk management.
- Scoring:
o Yes – lending policies are disclosed. Example: Lending
policies on mining industries – what ESG risks are they
review and mitigate. Separate disclosure/section in
AR/CSR about how they manage ESG risks or policy
related to it.
o Yes, but no information on scope or depth of policies – a
general mention that the company consider environmental
risks in their financing activities. No depth of policies
disclosed.
o Not Disclosed - default / if no evidence found
Management systems in place for assessing ESG risks in financing

activities
• Definition: Describes whether a company has management systems to
assess ESG risks in financing activities.
(a) Evidence of strong management systems in place for assessing ESG
risks in financing activities
(b) Some evidence of management systems in place for assessing ESG
risks in financing activities
(c) Existence of polices to assess ESG risks in financing activities, but no
evidence of supporting management system
(d) No evidence
• Keyword(s):
- Cannot provide keyword because data is qualitative and subjective
- We want to understand whether they have a legitimate and mature
system set-up to assess ESG risks.
- Existence of an EMS counts only if there is explicit reference to

assessing ESG risks in financing/credit.
- Equator Principle can be another guide to answer this datapoint. If the
company is an EP signatory, then they have these kinds of disclosures
about management systems.
- Common Sources:
o Check company website for standalone policies.
o Risk Management / ESG Policy section in AR/CSR
- Example:
- Scoring:
o Evidence of strong management systems in place for
assessing ESG risks in financing activities
• if evidence provided is advanced ESG credit
management system - look for evidence of pricing
mechanisms (i.e., linked their product pricing to ESG
performance of the borrower), loaning mechanism,
reduction of interest rate, etc. Avoid tokenistic
mention of ESG policy.
o Some evidence of management systems in place for
assessing ESG risks in financing activities –
• Score this option if there’s no mentioned of pricing
mechanisms (i.e., linked their product pricing to ESG
performance of the borrower), loaning mechanism,
reduction of interest rate, etc. but there is a general
statement of committee or mechanisms to manage
ESG risks.
o Existence of polices to assess ESG risks in financing
activities, but no evidence of supporting management
system
• There are policies in place but no management
system supporting these policies
• if there is any indication that company does
something to manage ESG risks in financing.
• Do not include any EMS to manage ESG operational
risks (e.g., to limit their environmental footprint,
sustainable procurement, energy efficiency, etc.).
Score ONLY as it applies to financing activities.
Equator Principles Signatory

• Definition: Indicates if the company is an Equator Principles Signatory.
(a) Yes
(b) No
(c) Not Disclosed
• Keyword(s):
'equator'
- Check in AR/CSR or in Equator Principles website
- Parent and Subsidiaries Procedure
o Case #1: Scoring a subsidiary and its parent company is an
EP Signatory
• Check whether the EP signatory applies to its
subsidiary, then this dp should be ‘Yes’
• This should not be scored as Yes unless there’s a
confirmation that it is also applies to the company
that we are assessing
o Case #2: Scoring a parent company and one of its
subsidiaries is an EP Signatory
• Check whether the EP signatory applies to its parent,
then this dp should be ‘Yes’.
• This should not be scored as Yes unless there’s a
confirmation that it is also applies to the company
that we are assessing
o Case #3 (Special Case): Scoring a parent company and one
of its subsidiaries is an EP Signatory. Example: the
company is involved in Investment Banking.
• Give credit to the dp under Scope of ESG due
diligence policy (operations covered) section.
• Only score the dp that fits the mentioned business
involvement. In the example, the company is
involved in Investment Banking, therefore, we only
mark Does the company's ESG due diligence policy
cover transaction under Investment Banking? as
‘Yes’.
Industry Guideline
o Turned off for Supranational but retained for Development
Banks. Leave this for the Content team to update.
Does the company state that it is a signatory or has adopted external

policies?
▪ Transport, Materials, Agriculture, Biodiversity, Climate Change, Energy Use,
Forestry, Mining, and Oil and Gas
• Definition: describes whether the company is a signatory or has adopted
external policies related to transport, materials, agriculture, biodiversity,
climate change, energy use, forestry, mining, and oil and gas industry
financing.
(a) Yes
(b) No
(c) No Evidence
• Keyword(s):
Use the industries/examples as keywords.
- Search for the following examples:
o Transport: - While there is no specific external body for it, if
there are internal policies developed by the company to
assess transport related risk or any organization mentioned
by the company in consultation with whom they frame
transport related policies, please document in internal
notes.
o Material: UNEPFI, SDG, EPA, GRI, IFC, Equator Principle
o Agriculture: PRI (responsible investment in farmland),
UNEFPI (new agriculture sector guide launched to help
financial institutions assess natural capital risk – still in
consideration), IFC (agriculture and forestry), SDG (Goal 2
Food security and nutrition and sustainable agriculture)
o Biodiversity: IFC Performance Standards, International
Cyanide Management code, World wildlife fund, Flora and
Fauna International, International Union for Conservation of
Nature (IUCN), Equator Principle, UNEFPI (United Nation
Environment Program Finance Initiative)
o Climate Change: IFC (International finance corporation),
Equator Principle, UNEPFI (united nation environment
program finance initiative), Sustainable Development Goals
(if investment measures are given)
o Energy Use: Environmental Protection Agency (EPA)
o Forestry: Equator Principle (covers forestry), IFC (covers
agribusiness and Forestry)
o Mining: IFC, GRI, Equator Principle and ICMM, UNEPRI
Oil and Gas: Extractive Industries Transparency Initiative

o
(EITI)
- Climate Change – Removed TCFD as evidence. For published data that
used TCFD as evidence, there’s no need to change to No evidence. This
will be applied moving forward.
Is there a ESG Lending/Credit policy

▪Transport, Materials, Agriculture, Biodiversity, Climate Change,
Energy Use, Forestry, Mining, and Oil and Gas
• Definition: describes whether the company is a signatory or has a ESG
Lending/Credit policy related to transport, materials, agriculture,
biodiversity, climate change, energy use, forestry, mining, and oil and gas
industry financing.
(a) Yes
(b) No
(c) No Evidence
• Keyword(s):
Use the industries/examples as keywords.
- Essentially what we are trying to capture here is if the company has
standalone policies or discloses some form of Environmental & Social
Policy / Risk Framework. For example, you may find disclosures such
as 'Company has developed its own binding environmental policy for
XXX sectors'.
- Company has specific policy for that specific sector to score ‘Yes’.
- We need to have ESG/credit policy where pricing related assessment
or parameters have been defined to reduce environmental
footprint/risk.
- Mere mention of lending for XXX does not mean that the company has
a lending/credit policy.
- Loan breakdown can be checked whether the company is lending to
these sectors. Then, check for the ESG/credit policy
reducing/mitigating the environmental footprint/risk.
- Search for the following examples:
o Transport: green transport, hybrid vehicles, solar cars etc.
o Material: environmentally friendly raw materials
o Agriculture: organic farming or some environment friendly
farming methods
o Biodiversity: businesses that save or work for the support
of biodiversity management
o Climate Change: loans that seeks to support mitigation and

adaptation actions that will address climate change.
o Energy Use: renewable sources of energy loans such as
solar panel loans, windmill loans, etc.
o Forestry: lending to save forestry and wildlife projects.
o Mining/Oil and Gas: lends to Mining/Oil and Gas industry
but mandates the loanee to follow some guideline
- In case there is any other activity apart from what is mentioned
above which deserves credit, please include in internal notes the
rationale behind giving it credit.
Are these policies subject to the same levels of scrutiny as binding credit
(formal lending) policies?
▪Transport, Materials, Agriculture, Biodiversity, Climate Change,
Energy Use, Forestry, Mining, and Oil and Gas
• Definition: describes whether the company’s policies are subject to the
same levels of scrutiny as binding credit (formal lending) policies.
(a) Yes
(b) No
(c) No Evidence
- The companies need to have specific lending/credit policies pertaining
to certain sectors.
- Before lending out, do these companies have policies to make sure that
the sectors they are lending have gone through due diligence and these
companies' operations don't lead to climate risks or impact climate in
a negative way.
- Dedicated policies that look for certain parameters before lending to
such industries. Conducting due diligence which they normally done
with their normal credit lending activities.
- Clear indication in disclosure that this is a credit policy, and therefore
subject to same auditing and internal controls as other credit policies.
- Binding credit – a formal lending policy mentioning the
conditions/terms of the company’s credit line.
o Example: If the bank says that they will not lend to
companies selling, helping, manufacturing, and/or selling
tobacco, they will subject all commercial loans to this
policy.
o If the company has still outstanding loan on the type of the

company they have excluded, then we should not consider
it as evidence.
Scope of ESG due diligence policy (operations covered)

• Case #3 from EP Signatory data point (Special Case): Scoring a parent
company and one of its subsidiaries is an EP Signatory. Example: the
company is involved in Investment Banking.
- Give credit to the dp under Scope of ESG due diligence policy
(operations covered) section.
- Only score the dp that fits the mentioned business involvement. In
the example, the company is involved in Investment Banking,
therefore, we only mark Does the company's ESG due diligence
policy cover transaction under Investment Banking? as ‘Yes’.
Does the company's ESG due diligence policy cover transaction under
Corporate Finance
• Definition: Indicates if the company has due diligence policy that covers
transaction under Corporate Finance
(a) Yes
(b) No
(c) No Evidence
• Keyword(s):
“corporate lending”, “commercial lending”, “wholesale lending”
“corporate lending”, “equity (equities) financing”, “debt (fixed income)
financing”, “investment banking”
- For Banks, search for key words and if ESG due diligence policy covers
any of the three categories, select “Yes” for this indicator.
o corporate lending
o commercial lending
o wholesale lending
- For Investment Banks, search for key words and if ESG due
diligence policy covers any of the three categories, select “Yes” for
this indicator.
o corporate lending
o equity (equities) financing
o debt (fixed income) financing
- For ‘investment banking’ keyword, check which part of the company

has this kind of operation (e.g., only parent or only one of its
subsidiaries). If the company we are profiling has investment
banking operation, then we mark this data point as ‘Yes’.
project finance (such as equator principles)?
transaction under project finance (such as equator principles).
(a) Yes
(b) No
(c) No Evidence
• Keyword(s):
“project finance”, “project loans”
- EP signatory
o Check the EP website or AR/CSR to know whether the
company has project finance. Then, check if the company
has due diligence for these projects.
o Note that if the company is an EP signatory, there is a high
probability the company has due diligence on project
finance transaction.
- Not EP signatory - If the company has project finance and ESG due
diligence policy or in-house policy applies to those projects, select
“Yes” for this indicator.
Investment Banking?
transaction under Investment Banking.
(a) Yes
(b) No
(c) No Evidence
• Keyword(s):
“investment banking”, “securities underwriting”, “equity underwriting”,
“debt underwriting”
- Search for keywords and if ESG due diligence policy covers any of these
categories, select “Yes” for this indicator.
o investment banking
o securities underwriting
o equity underwriting
o debt underwriting
- If one subsidiary is involved in investment banking subsidiary,
parent company mentioned that they have due diligence policy for
their investment banking transaction, then we score this as ‘Yes’.
Practices – Implementation and Oversight of ESG Due Diligence

Does the company's Group Credit Division conduct due diligence and
detailed assessments of its credit/lending portfolio on ESG issues?
• Definition: Indicates if the company's Group Credit Division conducts due
diligence and detailed assessments of its credit/lending portfolio on ESG
issues
(a) Yes
(b) No
(c) No Evidence
• Keyword(s):
'due diligence', 'ESG risk assessment’, ‘credit department’, ‘credit risk’,
‘credit team’
- We are looking for credit department along with credit underwriting
who apply the ESG policy of the company to do the due diligence to
their borrowers.
- Score if the company clearly stated that it conducts due diligence of
ESG Issues (e.g., CSR rating system designed to supplement the
environmental and social risk assessment)
- In addition, score if the company gives details of the due diligence
conducted (e.g., questionnaires, tools to map physical risks and
climate transition risks, etc.).
- General statements should not be considered in this data point. This
means if there’s no explicit disclosure that the credit team applies ESG
policies then, this data point should be scored as ‘No’.
- Be careful on disclosure on which CSR committee or other department
has oversight on financing/investing operations of the company but no
reference with their credit division. In that case, this datapoint should
still be scored as ‘No’.
Does the company provide details of ESG risk due diligence conducted by
it for its credit/lending products?
• Definition: Indicates if the if the company provides details of ESG risk due
diligence conducted for its credit/lending products
(a) Yes
(b) No
(c) No Evidence
• Keyword(s):
'due diligence', 'ESG risk assessment’
- High level overview of due diligence process
- The AR/CSR/SR reports would clearly mention or have a section
pertaining to ESG Due diligence practices followed by the company
while assessing their borrowers before lending to them.
- These policies would be over and above or integrated with the credit
policies of the company.
- These would broadly contain types of customers or transactions that
may expose them environmental risks. They might even mention the
thresholds explained below.
- Difference between Does the company's Group Credit Division conduct
due diligence and detailed assessments of its credit/lending portfolio
on ESG issues? and Does the company provide details of ESG risk due
diligence conducted by it for its credit/lending products
o Does the company provide details of ESG risk due diligence
conducted by it for its credit/lending products? –
information about due diligence process enforced by the
company
o Does the company's Group Credit Division conduct due
diligence and detailed assessments of its credit/lending
portfolio on ESG issues? – information about the execution
of the due diligence process. Meaning if the policy is
enforced by the credit risk team/division.
Number of project finance transactions reviewed against Equator

Principles or equivalent
• Definition: Indicates the number of project finance transactions reviewed
against Equator Principles or equivalent

• Keyword(s):
'project finance', 'Equator Principle'
- Check for AR/CSR/EP website for project finances transactions
reviewed against Equator Principle.
- If company is not EP signatory, then, leave blank.
- Normally the bank would disclose such transactions in their AR/CSR.
It would be a good practice to cross check with the Equator Principle
website to confirm the details.
- Additionally, in case the company has not disclosed details regarding
such transaction but say that they are a signatory to EP, please check
the EP website for number of transactions.
- If there’s no evidence found and there is a published data, please do
not delete and just retain the data.
Number of commercial customers/transactions subject to environmental

screen
• Definition: Indicates the number of commercial customers/transactions
subject to environmental screen
• Keyword(s): environmental screening
- Look for disclosures such company mentioning that XX number of
transactions or customers have been assessed under internally
developed ESG criteria.
- This should be all/total number of borrowers or transactions
assessed on certain parameters (i.e., this includes the EP)
- Check if the AR/CSR mention no. of commercial transactions that
have undergone environmental screening or assessed under
internally developed ESG criteria (for e.g., banks say XX number of
transactions underwent environmental screening). If no such
disclosures, then please leave it blank.
Formal training of risk officers and bankers on ESG risks and procedures
• Definition: Indicates if the company has formal training of risk officers and
bankers on ESG risks and procedures
(a) All banking staff trained on ESG risks and procedures, evidence of
legitimate ESG training programs provided
(b) Majority of credit risk staff trained on ESG risks and procedures
(c) Critical risk staff trained on ESG risks and procedures

(d) General statements on ESG training for employees
(e) Not Disclosed
• Keyword(s):
'training', 'ESG risk', ESG screening, ESG training
- Employees are being trained to apply the ESG policy that they have
in place while they are assessing their borrowers.
- Example: The company will mention in ESG policy that these are the
xx steps that they need to follow. And they mentioned that they
ensure that banking staffs are trained to apply these principles
when they are assessing their borrowers.
- Be careful on disclosure where the company mentioned that they
are providing ESG training to their employees. Since this data point
is about the employees in credit due diligence department. We are
looking for formal training of risk officers and bankers (who are
evaluating borrowers on different policies before they lend the
money).
- Scoring:
o All banking staff trained on ESG risks and procedures,
evidence of legitimate ESG training programs provided
• Do not score top level if details of trainings are not
provided, many banks say they provide training, but
basic compliance and awareness training does not
count of top indicators.
• Look for RI accreditation of training (best practice)
or external ESG consultant trainings.
• We are looking for legitimate ESG training that
specifically tackles ESG screening or ESG
rating/assessment
• Use this option if all employees that deal with
underwriting or loan disbursement are trained on
ESG risks and procedures and if legitimate ESG
training modules are detailed in company’s
disclosure.
o Majority of credit risk staff trained on ESG risks and
procedures
• Use this option if all employees that deal with
underwriting or loan disbursement are trained on
ESG risks and procedures.
o Critical risk staff trained on ESG risks and procedures
• Only specific risk officers and bankers within the

credit group department / risk management
department are trained.
-
ESG standards applied to subsidiaries or financial intermediaries (if

applicable)
• Definition: Indicates if company’s ESG standards apply to subsidiaries or
financial intermediaries
(a) Yes
(b) No
(c) Not Applicable
• Keyword(s):
' ESG standard’, ‘ESG governance’, ‘Sustainability governance’
- Answer ‘Not Applicable’ if the company has no subsidiaries.
- Duplicate data point but dropdown choices are different. If the
duplicate data point is not ‘Not Disclosed’ then, this should not be ‘No’
or ‘Not Applicable’
ESG standards applied to subsidiaries or financial intermediaries (if

applicable)
• Definition: Indicates if company’s ESG standards apply to subsidiaries or
financial intermediaries
(a) ESG standards applied to all subsidiaries, examples provided of
subsidiary due diligence
(b) ESG standards applied to all subsidiaries
(c) Not Disclosed
• Keyword(s):
- Is the same level of ESG standards applied to international
subsidiaries?
- Look for the primary lending businesses within the group’s corporate
structure, check to see if parent (rated entity) applies ESG standards to
child entities (mention of alignment between entity policies is ok if
subsidiary assessment is equally or more stringent than the parent – if
in doubt score conservatively).
- Group level assessment of ESG due diligence should include

consolidated reporting.
- Banks often make sweeping statements about applicability to all
subsidiaries. Score middle indicator option if there is an explicit
requirement for subsidiaries to abide by group ESG standards but no
examples of subsidiaries due diligence provided.
Ownership over ESG performance of the company's financing and

investment activities
• Definition: Indicates who has the owner ownership over ESG performance
of the company’s financing and investment activities
(a) Heads of Business or CEO
(b) Chief Risk Officer
(c) Dedicated Environmental and Social Risk Management Team
(d) CSR or Sustainability Committee
(e) Not disclosed or no clear responsibility
• Keyword(s):
- Watch out for differentiation between CSR team (e.g., reporting to
Communications or Corporate) vs ESG risk team (with some
connection to Risk Management team or function)
- If company clearly has a sustainability team, but it’s not clear where
they report, assume ‘CSR or Sustainability Committee’
- We should score based on the team who is responsible for the
oversight of ESG performance of the company's financing and
investment activities.
o Example: The Sustainability Committee is responsible for
the ESG performance of the company's financing and
investment activities and reports to the CEO. Then we
should not score this data point as ‘Heads of Business or
CEO’. The score should only be ‘CSR or Sustainability
Committee’.
Practices – Implementation of ESG Due Diligence

Involvement of Group Credit Risk in ESG due diligence
• Definition: Indicates the involvement of company’s Group Credit Risk in
ESG due diligence
(a) Yes
(b) No
(c) Not Disclosed
• Keyword(s):
'due diligence', 'credit risk', ’credit team’ ‘group credit level’
- Whether the company credit department incorporate the ESG
Policies along with their underwriting criteria or assessment
criteria while assessing their borrowers. In addition, team itself
have Execution and implementation those ESG policies.
- Scoring:
o Yes - if there are explicit examples of Group Credit
involvement in extra due diligence when an ESG issue is
flagged. Also, if there is a mention of credit involvement in
ESG due diligence (portfolio manager or analyst level can be
considered). ESG Risk Management is represented on
Credit Risk Committee or Credit Risk has defined
responsibilities in ESG risk management.
o No - if there is no mention of credit involvement (i.e., ESG
analysis is done by non-credit-professionals team (i.e., CSR
team))
Formal training of risk officers and bankers on ESG risks and procedures
• Definition: Indicates if the company has formal training of risk officers and
bankers on ESG risks and procedures
(a) Yes
(b) No
(c) Not Disclosed
• Keyword(s):
‘training’, ‘ESG Risk’
- Duplicate data point but dropdown choices are different.
- If the duplicate data point under Practices – Implementation and
Oversight of ESG Due Diligence is not ‘Not Disclosed’ then, this should
not be ‘No’ or ‘Not Disclosed
Number of corporate finance transactions reviewed on ESG criteria

(excluding Project Finance)
• Definition: Indicates the number of corporate finance transactions
reviewed on ESG criteria (excluding Project Finance)

• Keyword(s):
'corporate finance', ‘wholesale lending’, ‘commercial lending’, ‘corporate
lending’
- Check if Company’s corporate loan transactions, commercial loan
transactions or wholesale loan transactions are reviewed against
ESG criteria
- In case of issuers from "banks" industry - please check for
keywords like “corporate lending”, “commercial lending”,
“wholesale lending”.
- If the company has an ESG due diligence policy and the
transactions under above keywords and they quantify the
transactions which were executed after applying the said policy, the
no. of transactions to be mentioned here. The idea is to check the
extent of implementation of ESG due diligence policies to the
transactions undertaken by the company
- Exclude the project finance. Add the comment
Triggers and risk escalation processes clearly defined

• Definition: Indicates if the Company has clearly defined triggers and risk
escalation processes for customer/transaction that may require further
diligence.
(a) Yes
(b) No
(c) Not Disclosed
• Keyword(s):
‘risk escalation', 'risk assessment', ‘threshold’, ‘CO2’, Carbon emission’
- Does company mention threshold how ESG risks are identified? How
ESG risks are escalated to higher levels of due diligence?
- LITMUS TEST: For any given transaction, can you say how it would be
reviewed for ESG risks and by whom?
- This data point will be scored for companies that have ESG due
diligence policy. What we need to look at if there are thresholds
mentioned in the ESG policies on how they bucket / classified the
borrowers while assessing their ESG risk. Specifically, if they crossed
their normal lending policy, the assessment of such
clients/transactions require deeper due diligence or review of a senior
personnel.
- This can be found in ESG Policies, AR, CSR, or a rating mechanism

o Example in Green bond framework:
• Some companies disclosed that their borrowers
have certain level of Carbon emissions. Basically, if
they are on those ranges (threshold), the proceed of
green funds will be used to fund their requirements.
• Some companies who will mention their normal
lending which they can mention their borrowers are
going to reduce Carbon emissions and a certain
amount of carbon emission. If threshold is reach,
then ESG due diligence policies will mention what’s
the action the bank will take whether to funding or
reducing.
Practices - Triggers and risk escalation processes clearly

defined
Does the company provide only anecdotal examples of its products' ESG
risks?
• Definition: Indicates if the company provides only anecdotal examples of
its products' ESG risks
(a) Yes
(b) No
(c) Not Disclosed
• Keyword(s):
'risk escalation', 'risk assessment'
General Procedure:
- If the company provides only anecdotal examples of its products' ESG
risks. Anecdotal examples are given of cases (loans/deals) escalated
to senior committee for further due diligence.
- Under ESG Management or Risk Management section in AR/CSR.
o Risk management: They may mention a certain borrower or
loans for specific sector wherein there will be some breach
in terms of pricing related ESG triggers. Generally, mention
certain loans where they have process or triggers certain
aspect of ESG, or Sustainability requirement are breach they
will have enhanced ESG due diligence.
Does the company describe its ESG risk escalation process for its
credit/lending portfolio?
• Definition: Indicates if the company describes its ESG risk escalation
process for its credit/lending portfolio
(a) Yes
(b) No
(c) Not Disclosed
• Keyword(s):
General Procedure:
- Disclosure should be a ESG Risk Escalation Process which connects to
below datapoint (Does the company explain details of the outcome of
its products' ESG risk escalations along with examples?)
- These can be for existing loans being reviewed annually or for new
loans as well where borrowers are being assessed for the first time.
- Answers the following questions:
o How are ESG risks escalated to higher levels (e.g.,
Reputational Risk Committee)? On what basis and by
whom?
o How they are going to assess or manage those risk when
ESG risk are identified or address, does the company have
any certain steps or procedure need to follow for
escalating ESG risk?
Does the company explain details of the outcome of its products' ESG risk
escalations along with examples?
• Definition: Indicates if the company explains details of the outcome of its
products' ESG risk escalations along with examples.
(a) Yes
(b) No
(c) Not Disclosed
• Keyword(s):
- Outcome should mentioned the specific sector existing loan have
breached certain threshold so there is a triggers/ escalation metric.
Then answers the following questions:
o Does the company explain how ESG risks are identified?
o How are ESG risks escalated to higher levels (e.g.,

Reputational Risk Committee)? On what basis and by
whom?
o Do they disclose the outcome of these escalations (i.e., help
determine risks were acceptable/not)?
o Was there a pricing change (i.e., charging higher interest
rate for increased risk and/or cap loan size/bank risk
appetite)?
o Does it require ongoing monitoring?
o Would it benefit from engagement with the company?
Does the company provide threshold for escalation of its products' ESG
risks?
• Definition: Indicates if the Company provides a threshold (e.g., high risk,
medium risk, or low risk) for escalating the review of such
customers/transaction (for e.g., high risk in this case) for further review.
(a) Yes
(b) No
(c) No Evidence
• Keyword(s):
'risk escalation', 'risk assessment', ‘threshold’
- Check for disclosures regarding ESG due diligence policies
- Search for key words such ‘threshold’, ‘risk escalation’ to check if
company has provided any threshold for ESG risk escalation of
products
- Score only for those companies that have an ESG due diligence policy
in place. Depending on how the company scores the
clients/transactions.
- Example: they may assign a 'high risk', 'medium risk' or a 'low risk'
scoring.
- We need to look whether company clearly states that beyond what
threshold, let’s say in this case - companies scored 'high risk', would
require additional diligence or review by senior members/committees.
Does the company disclose the monetary value and volume of its products'
ESG risk escalations?
• Definition: Company discloses the amount of loans and the no. of loans
where threshold has been breached
(a) Yes
(b) No
(c) No Evidence
• Keyword(s):
- Check if company has disclosed the amount of loans or the no. of loans
that have crossed the threshold level and undergone additional due
diligence.
- Clients would be classified ESG Risk whether they are high risk or
medium risk or beyond quantified. Hence, anything beyond the
threshold would require additional due diligence.
- Hypothetically Examples:
o Companies who have exposure to mining industries loans up
to 5million dollars but anything beyond quantified such
number of transaction then there will have additional due
diligence.
o Generally, companies who have data breaches will provide
such details. For example, if oil spills happen, company that
had exposure, they are going to basically say their initially
exposure was provide loan of 100 thousand dollars. then
additional risk because of oil spills led to reputational risk or
a lot of litigation so all those causes is the monetary value of
that escalation.
- Any additional exposure who has over and above what has been
given to the borrowers wherein an additional cost that the bank
incurs because of that exposure to the event (or ESG Risk).
Does the company make general statements that it has ESG risk escalation
mechanisms for its products'?
• Definition: Indicates if the company makes general statements that it has
ESG risk escalation mechanisms for its products.
(a) Yes
(b) No
(c) No Evidence
• Keyword(s):
- Score if there is a general statement that company has ESG risk
escalation mechanisms for its products
- Please only score this indicator if none of the indicators above
(Practices - Triggers and risk escalation processes clearly
defined) had been scored with a "Yes". Otherwise, select "No
Value"
Practices – Evidence of board engagement with climate risk

Does the company's Board of Directors comprise of members who have
professional climate change competence/experience?
• Definition: Indicates if the company's Board of Directors comprises of
members who have professional climate change competence/experience.
• Keyword(s):
'board of directors’
- Score ‘Yes’ if there is a climate expert on the board of directors or
Board of Directors comprises of members who have professional
climate change competence/experience.
o Previous work related to climate
change/sustainability/environment/ESG
o Serving as board in climate-related organization
o Published a book or journal article or undertaken research
on climate change
- Other Source: Check CDP – Climate Change (C1. Governance)
where you can check competencies on climate change/climate
related issues.
Is there other evidence that the company's board of director's are generally
engaged on climate issues?
• Definition: Indicates if the company's Board of Directors are generally
engaged on climate issues.
(a) Yes
(b) No
(c) No Evidence
• Keyword(s):
- Score ‘Yes’ if the company's Board of Directors are generally
engaged on climate issues.
o Undertook/undertaking climate-related advocacies or
donated to climate-related initiatives
o Board talked about climate issues in AGM or board
meetings or media (e.g., press release, interviews, news
articles)
Is there evidence that the board of directors has implemented/influenced

a climate change business strategy/change such as coal financing/loan by
2025?
• Definition: Indicates if the company's Board of Directors have
implemented/influenced a climate change business strategy/change
(a) Yes
(b) No
(c) No Evidence
• Keyword(s):
'goals', 'targets', 'climate change', ‘limit financing’
- Score ‘Yes’ if there is evidence that the board has influenced some
form of change or requirement for business strategy to adhere.
(e.g., phase out of coal financing by 2025)
- Evidence wherein board control / auto manage the climate change
to push or propose discontinuing or limiting coal / oil / gas / fossil
fuel related financing by a target year.
Does the Chairman's Statement/CEO Statement have reference to climate

change?
• Definition: Indicates if the company's Chairman's Statement/CEO
Statement has reference to climate change.
(a) Yes
(b) No
(c) No Evidence
• Keyword(s):
- Score ‘Yes’ if CEO/Chairman provided a message in relation with
climate change.
- Look for the mention of climate change (or climate deniers) in the
chairman's statement (and CEO's if on board) or media.
o Do not give credit if Chairman / CEO just mention “Climate
Change” in the speech or statement.
o It should be an overview or oversee that they recognize the
climate change as a risk, and they do tackle / engage on
climate issues by mentioning on how the process or
procedure the company would mitigate the risk.
Environmental Opportunities – Offers sustainability consulting

services
Does the company consult with or participate with external sustainability
leaders such as the TCFD, PRI, UNEPFI, UNSDG?
• Definition: Indicates if the company consults with or participate with
external sustainability leaders such as the TCFD, PRI, UNEPFI, UNSDG,
PRB.
(a) Yes
(b) No
(c) No Evidence
• Keyword(s):
'TCFD'. 'PRI', 'UNEPFI'. 'UNSDG' ‘PRB’,
- Score ‘Yes’ if evidence is found on participation in pilot programs at
industry level, e.g., TCFD, PRI, UNEPFI, UNSDG consult.
- If the company consults with other organizations apart from the
ones mentioned here who according to their assessment is an
industry leader in promoting sustainability practices, please score
and include the details within the internal notes.
- Do not consider the Implementation on TCFD, PRI, UNEPFI, UNSDG,
PRB.
- Consulting or participation. There must be evidence specific
company we are evaluating for they should participating in forums
that create or solidified their industries or country. In consulting as
participant in that forum to SEC standard but not basically
implementing or following the standard.
Does the company generate at least 1% of global revenues from

sustainability consulting or corporate responsibility consulting or provides
sustainable solutions?
• Definition: Indicates if the company generates at least 1% of global
revenues from sustainability consulting or corporate responsibility
consulting or provides sustainable solutions.
(a) Yes
(b) No
(c) No Evidence
• Keyword(s):
'ESG', 'revenue'
- Check the generated revenues in Income Statement and look into
the notes for the breakup of the total revenue that company earns.
o Find the revenues related with sustainability consulting or
corporate responsibility consulting or provides sustainable
solutions and divide it to total revenue of the company.
• Examples: Revenues that they have provide set of
services from client, small banks, or external third
parties about how they can apply sustainability
actions or reports.
o If the result is at least 1% then, score 'Yes'.
Does the company state that it improves sustainability credentials of its

customers by changing the company's strategy and/or risk management
practices?
• Definition: Indicates if the company states that it improves sustainability
credentials of its customers by changing the company's strategy and/or
risk management practices
(a) Yes
(b) No
(c) No Evidence
• Keyword(s):
'risk management', 'strategy'
- Score 'Yes' if the company states on how they improve

sustainability credentials for their external clients (e.g., customer or
companies who wants to borrow) by changing the company's
strategy and/or risk management practices.
o Examples of common strategy / practices:
• They rate their companies who borrows from them
or on their finance. Through sustainability
committees who provides feedback on what needs
to be improve or what they lack on. Align to those
companies, to have certain sustainability or ESG
standard. This more like a consulting kind of
business line, on when they trying to improve their
sustainability credentials of their clients, customers
or companies who wants to borrow from them.
- This describes the company’s wider efforts to educate
stakeholders and markets to sustainability risks and opportunities.
- Do not provide point if they hire sustainability consulting services
of their own (e.g., from KPMG / EY / PWC). This should inform
strategy and risk management not product opportunity (though
outcome of the consulting may inform your scoring).
Does the company publish its own sustainability research report

addressing sustainability risks of customers/loanees?
• Definition: Indicates if the company publishes its own sustainability
research report addressing sustainability risks of customers/loanees
(a) Yes
(b) No
(c) No Evidence
• Keyword(s):
'research', 'sustainability report'
- Score 'Yes’ if company publishes (publicly) its own sustainability
research report addressing sustainability risks of
customers/loanees.
- This should be an information on their borrowers and if they follow
the ESG practices or sustainability on how they are performing and
meeting barriers or targets
o This should be a detailed information about their own
exposure or companies who have they lent to. By trying to
assess on how they are performing ESG practices and
disclosing to the third parties (e.g., stakeholders,

shareholders, outside investors).
o Do not score if they give general disclosure about currently
climate risk how they tackled
- Access the Company website for the disclosure of the snapshot
loan table and sustainability loan reports.
Environmental Opportunities – Involvement in Green Bonds

Does the company offer green bond structuring/consulting services?
• Definition: Indicates if the company offers green bond
structuring/consulting services
(a) Yes
(b) No
(c) No Evidence
• Keyword(s):
'green bonds', ’green bond framework’
- Check Company website where they disclose: Green Bond
Framework or Green Bond Report.
- Here we are scoring the banks’ issuing green bonds themselves or
they are an arranger / underwriter for other company green bond
transaction.
- If the bank can structure/underwrite green bonds it implies much
higher knowledge of the green bonds space, as well as
interconnectivity with engaged green investors. This suggests
better placement to evolve into product development opportunities
as the space matures.
- Do not give credit if they only mention investing in green bonds.
- They are promoting or consulting service for green bonds.
Is there any evidence that the company has undertaken green

bond/climate bonds/sustainable bond initiatives in the past two years?
• Definition: Indicates if there is any evidence that the company has
undertaken green bond/climate bonds/sustainable bond initiatives in the
past two years.
(a) Yes
(b) No
(c) No Evidence
• Keyword(s):
'green bonds', 'climate bonds', 'sustainable bonds'
- Score 'Yes' if there is any evidence that the company has
undertaken green bond/climate bonds/sustainable bond initiatives
in the past two years.
o Initiative: Does the company issued/ underwrites the bond
to create or fund the project and mention how much or
amount of issued green bond/climate bonds/sustainable
bond they have raised?
Has the company invested more than USD 1 Billion in green bonds or
climate bonds or sustainable development bonds?
• Definition: Indicates if the company invested more than USD 1 Billion in
green bonds, climate bonds, or sustainable development bonds.
(a) Yes
(b) No
(c) No Evidence
• Keyword(s):
- Score 'Yes’ if the company significant investment (more than USD
1 Billion in green bonds, climate bonds, or sustainable
development)
- Update based on disclosures in the most recent year
Has the company set targets to increase its investments in green bonds or
climate bonds or sustainable development bonds?
• Definition: Indicates if the company sets targets to increase its
investments in green bonds or climate bonds or sustainable development
bonds.
(a) Yes
(b) No
(c) No Evidence
• Keyword(s):
- Aside from AR CSR, this is usually can be found in sustainability

presentation.
- Score 'Yes’ if the company sets significant targets to increase its
investments in green bonds, climate bonds, or sustainable
development bonds.
- Target disclosure must be a quantified which mention the amount
of green bonds they would raise in long term view (e, g. Next 2 years
or 5 years). Please be noted that this should be a fresh issuance.
- Do not score if they only disclose in general information on
increasing investment in green bonds.
Environmental Opportunities – Sustainability related product

development
NOTE: Please answer this section based on the sequence of the data points.
Does the company incorporate/sell products such as loans that have

sustainability mechanisms embedded in them?
• Definition: Indicates if the company incorporates/sells products such as
loans that have sustainability mechanisms embedded in them.
(a) Yes
(b) No
(c) No Evidence
• Keyword(s):
'sustainable’, 'loans', ‘green loans’, ‘green mortgage loans’, ‘green deposit’,
‘green commercial loan’
- Score ‘Yes’ if company mentions they have loans with in-built
sustainability features and the end use of such loans is for
sustainability focused activities. This datapoint is more on general
reference.
- Example: Loan for activities involving reduction of carbon footprint
- These may also include loans whose pricing is linked to the ESG
performance of the borrower. Idea is to give credit for such
products which induces the borrower to apply ESG metrics in its
business activities by using the borrowed funds.
- Try looking for products whose end use is tied for undertaking
sustainable activities.
- Interlinked with: “Does the company currently derive between 0%

and 1 % of revenues from such products?” and “Does the company
currently derive more than 1% of revenues from such products?”
o Once they have sustainability disclosure embedded then we
would find a reference to revenue or assets that are
prolonged basically in their products (company offer).
o The disclosure pointing out the amount / exposure
information whether they derived a revenue from such
products then we could score one of the two datapoints.
Does the company currently derive between 0% and 1 % of revenues from

such products?
Does the company currently derive more than 1% of revenues from such
products?
• Definition: Indicates the percentage of revenue (i.e., between 0% - 1% or
more than 1%) from sustainability products.
(a) Yes
(b) No
(c) No Evidence
• Keyword(s):
'loans', 'sustainable', 'financial products', ‘green loans’, ‘green mortgage
loans’, ‘green deposit’, ‘green commercial loan’
- Products pertains to sustainability products in previous section
‘Sustainability related product development’.
- Score 'Yes' if company currently derives between 0%-1% or more
than 1% of revenues from sustainability related financial products.
- Note: if ‘Does the company currently derive more than 1% of
revenues from such products?’ answered ‘Yes’ that then, ‘Does the
company currently derive between 0% and 1 % of revenues from
such products?’ would be answered ‘Yes’ as well.
Evidence of sustainability related financial products but no links to pricing.

• Definition: Indicates if the company has a sustainability related financial
products but no links to pricing.
(a) Yes
(b) No
(c) No Evidence
• Keyword(s):
- Score 'Yes' if company makes some mention of sustainability
related financial products but no links to pricing.
- Example: simple financing of green buildings (not own buildings),
or specialized loan team for sustainability sector.
- If the company mention, if they have green loans or green mortgage
loans or green deposit that means they have product but then if that
the only mention general disclosure then we score this.
Is there some evidence of product pricing based on customer ESG

performance?
• Definition: Indicates if the company has product pricing based on
customer ESG performance
(a) Yes
(b) No
(c) No Evidence
• Keyword(s):
- Score ‘Yes' if there is some evidence of product pricing based on
customer ESG performance. Sophisticated products with pricing
links to sustainability mechanisms also suggest advanced
knowledge in understanding sustainability data and offer a small
proxy for ability to translate into/from ESG risk management. This
needs to be recent (within last two years).
- Pricing links such as efficiency loans (e.g., discounts for energy
efficiency) or product pricing linking sustainability outcomes on
issuer performance (usually loans) can be considered.
- Examples provided of first-of-its kind innovative financial products
(e.g., ING with ESG Rating linked loan pricing).
Environmental Opportunities – Impact related product

development
NOTE: This an investment related to any of the 17 Sustainable Development Goals
(SDG). This should be an investment not a loan.
We are looking if the company issues SDG bonds or SDG linked products to raise
funds and use those funds to finance loans which directly promote or comply with
the 17 SDGs laid down by the UN.
In addition, we can also consider if the company provide evidence on what they have
invested or created product related to SDG Goals or impact on social benefit bonds
either underwritten or invested in.
Standard green bonds do not count as this is already considered in another indicator.
Source: No need to go to specific bonds (framework) disclosure to figure out the
datapoint. It will be available in AR/CSR/ Issuer Presentation/Investment
Presentation.
Please answer this section based on the sequence of the data points.
Is there any evidence that the company develops products by aligning

them with SDG goals?
• Definition: Indicates if the has any evidence that the company develops
products by aligning them with SDG goals.
(a) Yes
(b) No
(c) No Evidence
• Keyword(s):
'SDG'
- This would be scored if the company who are opting ESG for the
first time or have existing product which had evidence on
developing product design to align or meet the SDG Goals.
Has the company developed its own impact products such as Social Commented [ACJ51]: This procedure can be used
Benefit/Impact Bond, SDG-linked products, etc.? while profiling.
• Definition: Indicates if the company developed its own impact products Ops: Pending Validation to be created.
such as Social Benefit/Impact Bond, SDG-linked products, etc. If this datapoint is Yes then this should not be No or No
evidence Is there any evidence that the company
• Dropdown choices: develops products by aligning them with SDG goals?
(a) Yes
(b) No
(c) No Evidence
• Keyword(s):
'SDG'
- Score 'Yes' if can find some evidence of product development in the
impact space
o Example: They develop products with explicit links to
environmental / social impact. Quantitative outcomes such
as lives saved, carbon emission avoided, trees planted, etc.
- There will be a process when they will create their own product
based on their experience or whether they have already developed
own products in one of the impact spaces.
- Essentially giving benefit to the company if they are developing
such SDG bonds/other SDG focused instruments to raise funds for
financing SDG compliant activities.
- Interlinked: if this is a “Yes” then this should be scored as “Yes” –
“Is there any evidence that the company develops products by
aligning them with SDG goals?”.
Has the company invested more than USD 100 million towards impact
investments in the previous two years?
• Definition: Indicates if the company invested more than USD 100 million
towards impact investments in the previous two years.
(a) Yes
(b) No
(c) No Evidence
• Keyword(s):
'responsible investment', 'ESG'. 'sustainability
- This indicator is explicitly looking at "impact", given the growing
demand specifically for “impact” or SDG related products.
- Score 'Yes' if they already had investments in impact investing that
total outstanding is more than USD 100 million, data must be from
the last two years.
o Example: Manila municipality raised a social bond which
would fund the local school. The banks basically would
invest money in that bond which has specific social impact
Targets for impact investing greater than USD 100 million in the coming 2
years?
• Definition: Indicates if the company has targets for impact investing
greater than USD 100 million in the coming 2 years.
(a) Yes
(b) No
(c) No Evidence
• Keyword(s):
'responsible investment', 'ESG'. 'sustainability'
- Score if the company has targets or plan for impact investing
greater than USD 100 million in the coming 2 years.
- We want to know what the company’s near-term targets are in
terms of impact investment. We should check for targets for the
next 2 years only.
- Targets must be more than current investment levels.
Environmental Opportunities – Company conducts climate

change risk analysis
NOTE: Please answer this section based on the sequence of the data points.
Does the company provide only anecdotal evidence or makes general

statements on climate change risks?
• Definition: Indicates if the company provides only anecdotal evidence or
makes general statements on climate change risks
(a) Yes
(b) No
(c) No Evidence
• Keyword(s):
‘climate change’
- Any kind of reference on climate change risk.
- We can search on the CEO has mention in climate risks, if the CEO
describes how they assess the risk (e.g., materiality assessment,
assessment of their environmental exposure, etc.), then we can
score this data point as ‘Yes’
- For companies do project finance or EP, this data point is

automatically scored as ‘Yes’
Evidence of aligning its loan/credit portfolio with Task Force on Climate-

related Financial Disclosures (TCFD)?
• Definition: Indicates f there is any evidence of aligning its loan/credit
portfolio with Task Force on Climate-related Financial Disclosures (TCFD)
(a) Yes
(b) No
(c) No Evidence
• Keyword(s):
'TCFD'
- Score 'Yes' if there is any evidence of aligning its loan/credit
portfolio with Task Force on Climate-related Financial Disclosures
(TCFD)
- Company provides information on their loan or credit portfolio in
reference to materiality analysis.
o Example: Against their loan portfolio, xx million have direct
impact on climate change.
Does the company conduct climate sensitivity assessments linked to

financial ratios?
• Definition: Indicates if company conducts climate sensitivity assessments
linked to financial ratios.
(a) Yes
(b) No
(c) No Evidence
• Keyword(s):
'climate sensitivity'. 'financial ratios'
- Score 'Yes' if company conducts climate sensitivity assessments
linked to financial ratios.
- If they reference any kind of impact based on the loans that have
exposure to climate change risk. And because of that exposure
there will be an impact on their financial ratios.
Does the company conduct or steer climate scenario analysis such as

degrees of warming?
• Definition: Indicates if company conducts or steers climate scenario
analysis such as degrees of warming
(a) Yes
(b) No
(c) No Evidence
• Keyword(s):
'climate scenario'
- Score 'Yes' if company conducts or steers climate scenario analysis
such as degrees of warming.
- If the company explicitly disclosed that they have done the steer
climate scenario analysis on their loans, we score this data point as
‘Yes’.
- We check for evidence on the impact of issuers on degrees of
warming due to their operations. Hence, we check for loan portfolio.
- Do not consider those disclosure about their own operational
footprint (Example: Reducing office carbon footprint)
Does the company conduct climate sensitivity assessments (such as

climate VAR or utilize internal carbon price) prior to lending to corporates?
• Definition: Indicates if the company conduct climate sensitivity
assessments (such as climate VAR or utilize internal carbon price) prior to
lending to corporates.
(a) Yes
(b) No
(c) No Evidence
• Keyword(s):
- Score 'Yes' if the company conducts climate sensitivity
assessments (such as climate VAR or utilize internal carbon price)
prior to lending to corporates
- What are the parameters/metrics that the company has used to do
climate sensitivity assessments on their loan portfolio or while
lending to specific companies?
Evidence of materiality assessment of group-wide business risks

associated with climate change such as scenario modelling/sensitivity
analysis? Commented [LRA52]: This procedure can be used
• Definition: Indicates company’s materiality assessment of group-wide while profiling.
business risks associated with climate change such as scenario Ops: Pending Validation to be created.
modelling/sensitivity analysis If all datapoints below is answered as Yes, then this is
• Dropdown choices: the only time that we answer this data point as ‘Yes’.
(a) Yes
(b) No
(c) No Evidence
• Keyword(s):
'scenario modelling', 'sensitivity analysis', 'materiality'
- Score 'Yes' if evidence is found of at least one of the following:
o climate scenario analysis (e.g., degrees warming),
o climate sensitivity assessments (e.g., to financial ratios),
OR
o deep dive on exposed industries (e.g., bespoke case
studies)
- If all datapoints below is answered as Yes, then this is the only time
that we answer this data point as ‘Yes’.
o Does the company provide only anecdotal evidence or
makes general statements on climate change risks?
o Evidence of aligning its loan/credit portfolio with Task Force
on Climate-related Financial Disclosures (TCFD)?
o Does the company conduct climate sensitivity assessments
linked to financial ratios?
o Does the company conduct or steer climate scenario
analysis such as degrees of warming?
o Does the company conduct climate sensitivity assessments
(such as climate VAR or utilize internal carbon price) prior
to lending to corporates?
Health & Safety

This issue evaluates the extent to which companies may face employee accidents
that can lead to production disruptions, litigation, and liabilities. Scores are based on
exposure to businesses and geographies facing high accident rates; H&S targets and
oversight; and accident rates and fatalities over time and vs. peers.
General Guidance for Health & Safety Performance tables

(LTIR, TRIR, Other H&S Metric)
- Only add rows if there is evidence found. Delete blank published rows if there
is no disclosure
- For issuers that disclosed TRIR and LTIR for employees and contractor data
separately
o Provide clear Internal Notes and correct sources (e.g. report, page
number, link)
o Prioritize employee data for the Lost Time Incident Rate and Total
Recordable Injury Rate tables
o Place the separate LTIR and/or TRIR contractor data in the Other H&S
Metric table
▪ LTIR and TRIR Contractor data will have a No Value score for
the Scope of Reported Other Health & Safety Metric datapoint
▪ Indicate in the Details field in the table that data is only for
contractors and provide Internal Notes
Performance – Operations – Lost Time Incident Rate

Lost Time Incident Rate Commented [ACJ53]: Pending to Content:
• Definition: This data point refers to the lost time incident rate of the
Definition – standard definition to be sent by content
company. Lost time incident rate refers to the rate of employees unable to (Von)
work due to injuries/incidents
Commented [ACJ54]: Industrial: LTIR is the number of
• Dropdown choices: accidents that resulted in time lost from work of one
N/A – input value day/shift or more per hours worked.
• Keyword(s):
LTIR is also called Lost Time Case Rates, Lost Workday
Lost Time Incident Rate, Lost Time Injury Rate, LTIR, Lost-Time, Lost Time Incidence Rates, Lost Time Injury Frequency, accidents
• General Procedure: leading to medical leave. Generally, when the company
- Place in the value of the lost time incident rate presented by the specifies that its disclosure is for accidents that led to
employee absences, this data can be considered as
company LTIR.
- Never calculate the average/total H&S data if the company only
provided contractor and employee data separately. In these cases,
see General Guidance for Health & Safety Performance tables

- They usually disclose these in their environmental performance
tables at the end of their reports or on their Health & Safety section
of the report
Lost Time Incident Rate Unit

• Definition: This data point refers to the unit used by the company in
reporting their lost time incident rate
(a) per 100 employees
(b) per 500 employees
(c) per 1,000 employees
(d) per 100,000 employees
(e) per 1,000 hours
(f) per 100,000 hours
(g) per 200,000 hours
(h) per million hours
• Keyword(s):
Lost Time Incident Rate, Lost Time Injury Rate, LTIR, Lost-Time, Lost Time
- Place in the unit of the lost time incident rate presented by the
company
of the report
- For companies which do not report the unit but follow the OHSA
reporting, we can assume a per 200,000 hours unit (ensure there is
clear statements that the company follows OHSA reporting) Commented [LRA55]: How about for Riddor?
Details
• Definition: This data point refers to the additional information on the
company’s reported lost time incident rate
N/A – free text
• Keyword(s):
- Place in additional information on the lost time incident rate of the
company. E.g., title of the H&S Lost Time Incident Rate data, scope
of data (employees or both employees and contractors; scope of

operations); If there is no detail provided, leave as blank
of the report
Scope of Reported Lost Time Incident Rate

• Definition: This data point refers to the scope/coverage of the company’s
data on lost time incident rate
(a) Covers all relevant operations or product segments - Employees and
Contractors
(b) Covers all relevant operations or product segments - Employees only
(c) Covers selected operations or product segments - Employees and
Contractors
(d) Covers selected operations or product segments - Employees only
(e) Scope not determinable
• Keyword(s):
- Place in the scope of the lost time incident rate presented by the
company
of the report
- Scoring
o Covers all relevant operations or product segments -
Employees and Contractors - the company’s LTIR data
reports are on both employees and contractors in all
locations; ensure that the data scope reports for all
operations
Employees only - the company’s LTIR data reports are on
both employees only in all locations; ensure that the data
scope reports for all operations
o Covers selected operations or product segments -
Employees and Contractors - the company’s LTIR data
reports are on both employees and contractors in selected
locations; if the company operates in multiple operations
and they only stated that the data is only for a selected
location/operation, use this score

Employees only - the company’s LTIR data reports are only
on employees in selected locations; if the company
operates in multiple operations and they only stated that the
data is only for a selected location/operation, use this score
o Scope not determinable = the company’s LTIR data is
presented but there is no scope disclosed (there is no
statement if the data is pertaining to employees, both
employees and contractors, all operations, or selected
operations)
Performance – Operations – Total Recordable Injury Rate

Total Recordable Injury Rate Commented [ACJ56]: Pending to Content:
• Definition: This data point refers to the total recordable injury rate of the
Definition – standard definition to be sent by content
company (Von)
Commented [SAM57]: Definition:
N/A – input value Joyee - TRIR is also called OSHA Reportable Incidents,
• Keyword(s): Accident Frequency Rate, Total Recordable Accident
Total Recordable Injury Rate, Total Recordable Incident Rate, TRIR Rate. When there is the possibility that the company’s
disclosed incident rates include accidents that did not
• General Procedure: lead to lost time (e.g., near-misses, first aid injuries),
- Place in the value of the total recordable injury rate presented by such disclosure must be inputted in the TRIR field
the company
of the report
Total Recordable Injury Rate Unit

• Definition: This data point refers to the unit used by the company in
reporting their total recordable injury rate
(a) per 100 employees
(b) per 500 employees
(c) per 1,000 employees
(d) per 100,000 employees
(e) per 1,000 hours
(f) per 100,000 hours
(g) per 200,000 hours
(h) per million hours

• Keyword(s):
Total Recordable Injury Rate, Total Recordable Incident Rate, TRIR
- Place in the unit of the total recordable injury rate presented by the
company
of the report
clear statements that the company follows OHSA reporting) Commented [LRA58]: How about for Riddor?
Details
• Definition: This data point refers to the additional information on the
company’s reported total recordable injury rate
N/A – free text
• Keyword(s):
- Place in additional information on the total recordable injury rate of
the company. E.g., title of the H&S Total Recordable Injury Rate
data, scope of data (employees or both employees and contractors;
scope of operations); If there is no detail provided, leave as blank
of the report
Scope of Reported Total Recordable Injury Rate

data on total recordable injury rate
Contractors
Contractors
• Keyword(s):
- Place in the scope the total recordable injury rate presented by the
company
of the report
- Scoring
Employees and Contractors - the company’s TRIR data
reports are on both employees and contractors in all
operations
Employees only - the company’s TRIR data reports are on
both employees only in all locations; ensure that the data
Employees and Contractors - the company’s TRIR data
reports are on both employees and contractors in selected
locations; if the company operates in multiple operations
and they only stated that the data is only for a selected
location/operation, use this score
Employees only - the company’s TRIR data reports are only
on employees in selected locations; if the company
o Scope not determinable - the company’s TRIR data is
operations)
Performance – Operations – Fatalities

Employee Fatalities
• Definition: This data point refers to the company’s employee
fatalities/deaths for the year
N/A – input value
• Keyword(s):
Fatalities, Death, Fatal, Fatality, Employee Death, Employee Fatalities,

Employee Fatality
- Place in the total employee fatalities presented by the company
o Employee fatality rates are NOT valid; use the disclosed
actual number of employee fatalities (absolute values)
o If the company did not disclose employee fatalities and only
disclosed fatalities, leave this data point blank and put the
data under the Fatalities data point
o Do not put zero when there was no evidence found. Only put
zero when the company explicitly disclosed zero employee
fatalities/no employee fatalities were recorded
of the report
Contractor Fatalities
• Definition: This data point refers to the company’s contractor
fatalities/deaths for the year
N/A – input value
• Keyword(s):
Fatalities, Death, Fatal, Fatality, Contractor Death, Contractor Fatalities,
Contractor Fatality
- Place in the total contractor fatalities presented by the company
o Contractor fatality rates are NOT valid; use the disclosed
actual number of contractor fatalities (absolute values)
o If the company did not disclose contractor fatalities and
only disclosed fatalities, leave this data point blank and put
the data under the Fatalities data point
zero when the company explicitly disclosed zero contractor
fatalities/no contractor fatalities were recorded
of the report
Fatalities
• Definition: This data point refers to the company’s total fatalities/deaths
for the year
N/A – input value

• Keyword(s):
Fatalities, Death, Fatal
- Place in the total fatalities presented by the company
o Fatality rates are NOT valid; use the disclosed actual
number of fatalities (absolute values)
o If the company disclosed both employee, contractor, and
non-company fatalities, this will be the sum of all three
zero when the company explicitly disclosed zero
fatalities/no fatalities were recorded
of the report
Details
N/A – free text
• Keyword(s):
Fatalities, Death, Fatal
- Place in the details of the fatalities presented by the company; If
there is no detail provided, leave as blank
of the report
External (non-company) fatalities

• Definition: This data point refers to the non-employees/non-contractors
death/fatalities caused by the company’s operations for the year
N/A – input value
• Keyword(s):
Fatalities, Death, Fatal, Non-company fatalities, Non-company fatality
- Place in the non-company fatalities (regular citizen fatalities)
presented by the company
zero when the company explicitly disclosed zero non-
company or citizen fatalities/no non-company or citizen
fatalities were recorded
- Unlike the employee/contractor/total fatalities, this disclosure is

usually found in the CEO’s opening statement at the start of the
report
Performance – Operations – Other H&S Metric

Other Health & Safety Metric Description
• Definition: This data point refers to the company’s Health & Safety data
that is neither Lost Time Incident Rate, Total Recordable Injury Rate, nor
Fatalities
N/A – free text
• Keyword(s):
Accident, Injury
- Place in the name of the other H&S data presented by the company
o Ensure that the data is not Lost Time
Injury/Frequency/Incident Rate, Total Recordable
Injury/Incident Rate, or Fatalities/Deaths since these have
specific tables (Lost Time Incident Rate, Total Recordable
Injury Rate, Fatalities tables)
• EXCEPTION: LTIR and TRIR for contractors. See
General Guidance for Health & Safety Performance
tables (LTIR, TRIR, Other H&S Metric) for more
details
of the report.
Other Health & Safety Metric Value

• Definition: This data point refers to the company’s Health & Safety data
(value) that is neither Lost Time Incident Rate, Total Recordable Injury Rate,
nor Fatalities
N/A – input value
• Keyword(s):
Accident, Injury
- Place in the value of the other H&S data presented by the company

details
of the report
Details
• Definition: This data point refers to the addition information on the
company’s Health & Safety data that is neither Lost Time Incident Rate,
Total Recordable Injury Rate, nor Fatalities
N/A – free text
• Keyword(s):
Accident, Injury
- Place in additional information on the other H&S data of the
company. E.g., reporting unit and/or scope of data (employees,
contractors, or both employees and contractors; scope of
operations, etc.); If there is no detail provided, leave as blank
clear statements that the company follows OHSA reporting)
of the report
Scope of Reported Other Health & Safety Metric

Health & Safety data that is neither Lost Time Incident Rate, Total
Recordable Injury Rate, nor Fatalities

Contractors
Contractors
• Keyword(s):
Accident, Injury
- Place in the scope of the other H&S data presented by the company
details
of the report
reporting, we can assume a per 200,000 hours unit
- Scoring
Employees and Contractors - the company’s Other H&S
data reports are on both employees and contractors in all
operations
Employees only - the company’s Other H&S data reports are
on both employees only in all locations; ensure that the data
Employees and Contractors - the company’s Other H&S
data reports are on both employees and contractors in
selected locations; if the company operates in multiple
operations and they only stated that the data is only for a
selected location/operation, use this score

Employees only - the company’s Other H&S data reports are
only on employees in selected locations; if the company
o Scope not determinable - the company’s Other H&S data is
operations)
Practices – Governance & Strategy

Health & safety performance as factor in executive compensation
• Definition: This data point refers to the whether the company has an
executive compensation/incentive on the Health & Safety performance for
the year
(a) Yes
(b) No
(c) Not Disclosed
• Keyword(s):
Executive compensation, annual bonus, STI, Short-Term Incentive, Short
Term Incentive, LTI, Long-Term Incentive, Long Term Incentive, ESG
compensation, Health & Safety incentive, Health & Safety bonus, Health
and Safety incentive, Health and Safety bonus, H&S incentive, H&S bonus,
Health and Safety, H&S, Health & Safety, long-term award, short-term
award, long term award, short term award, ESG criteria, Safety criteria, H&S
criteria, H&S metrics, Safety metrics
- H&S compensation criteria are usually found in their Short-term
incentive plan (STI) or Long-term incentive plan (LTI)
- Can also be found as a general statement in their CSR/AR
- This must be for executives and not employees
- Scoring
o Yes - if the company has bonus/incentive for executives
when the company achieves a certain H&S metric in their
compensation plan/incentive plan; score even if the
company only mentioned they have H&S metrics/criteria in
their executive compensation
o No - if the company mentioned that they do not have a
bonus/incentive for executives when the company achieves
a certain H&S metric in their compensation plan/incentive

plan
o Not Disclosed - no information found
Percentage of the company's health & safety system certified to OHSAS

18001
• Definition: This data point refers to the percentage of the company’s
operations/health & safety systems that are certified to OHSAS 18001 or
ISO 45001
N/A – input value
• Keyword(s):
OHSAS 18001, OHSAS-18001, OHSAS18001, ISO 45001, ISO-45001,
ISO45001
- Input the percentage of the company’s operations certified to
OHSAS 18001 or ISO 45001 ONLY
o Ensure that company is explicitly certified and not only
“aligned to”, “follows”, “patterned to”, “adhere to”, etc.
o If no percentage disclosed, calculate by: Total operations
certified/Total operations *100
o If the total operations cannot be identified, do not score this
data point since we cannot assume the total number of
operations of a company
- Do not place zero (0) if there is no disclosure/evidence found.
Delete the published zero value if no evidence/disclosure found.
Evidence of company having a certified Health & Safety system Commented [SAM59]: Pending to Content:
• Definition: This data point refers to the certification scope of the
Content team to check if there are other H&S
company’s Health & Safety system certifications that specific industries consider
(a) All relevant operations are estimated to be certified
(b) Selected relevant operations are estimated to be certified
(c) General statements on Health & Safety certification system
(d) No evidence
• Keyword(s):
ISO45001, Health & Safety management system, H&S system, Health &
Safety system, Health and Safety management system, H&S certification,
Health & Safety certification, Health and Safety certification, GB/T28001-
2011
- All kinds of H&S certifications are VALID. Indicate disclosure and
certification in the Internal Notes
o The common H&S certification systems are ISO
45001/OHSAS 18001 and GB/T28001-2011 (for China
issuers)
- Scoring
o All relevant operations are estimated to be certified - all
operations are certified to H&S certification systems
o Selected relevant operations are estimated to be certified -
only a certain number of operations are certified to H&S
certification systems; use this score if the company
mentions specific sites (but not all sites) that are certified
to H&S certification systems
o General statements on Health & Safety certification
system - there is only a general statement that the
company’s operations are certified to H&S certification
systems (no details or mention of the site/operations
certified, locations certified, the specific certification, etc.)
o No evidence - no information found.
China A
o For China-based issuers, in addition to ISO 45001, the local
certification GB/T 45001-2020 (also GB/T 28001-2011) also
counts.
- China A default (General statements on H&S certification system) is
discontinued.
Inclusion of contractors in health & safety metrics

• Definition: This data point refers to whether the company’s health & safety
data includes contractors
(a) Yes
(b) No
(c) Not Disclosed
• Keyword(s):
Contractor LTIR, Contractor Lost-Time, Contractor Total Recordable,
Contractor TRIR, Contractor death, Contractor fatality, Contractor fatalities,
Contractor accident
- If there are H&S quantitative data (LTIR, TRIR, etc), identify if the
company also has contractor data
- Scoring
o Yes - the company includes contractors in their H&S data
(contractor LTIR, TRIR, Fatalities, Other H&S data)
o No - the company mentioned that they do not include
contractors/explicitly mentioned that their H&S data are
only for employees
o Not Disclosed - no evidence found/there is no clear
evidence if the data are for employees only or includes
contractors
Practices - Governance and Strategy - Health & safety policy

H&S policy is group-wide
• Definition: This data point refers to the (group-wide) scope/applicability of
the company’s H&S policy
(a) Yes
(b) No
(c) Not Disclosed
• Keyword(s):
Scope, H&S policy, Health & Safety Policy, Health and Safety Policy
- Identify if the H&S policy of the company is for the whole
group/whole company
- Ensure that the H&S policy is the internal H&S policy of the company
(not the company’s H&S policy for suppliers/business
partners/customers/consumers/etc.)
- Scoring
o Yes - the company’s policy is group-wide/covers all
geographic locations where they operate; use this score if
company has ISO 45001/OHSAS 18001 certification for
100% of their operations (ensure that company is explicitly
certified)
o No - the company explicitly stated that their H&S policy does
not cover all geographic locations where they operate or
only covers selected operations
o Not Disclosed - no evidence
JP IMI
- Sub-Industry: All
- Default Scoring: Yes, if majority of assets are in JP
Market Guidelines
- Market: Developed Market
China A
o For China-based issuers, if the company has local
certification GB/T 45001-2020 (or GB/T 28001-2011) for
100% of its operations, credit Yes.
H&S policy applies to contractors

• Definition: This data point refers to the applicability of the company’s H&S
policy to contractors
(a) Yes
(b) No
(c) Not Disclosed
• Keyword(s):
Contractor, H&S policy, Health & Safety Policy, Health and Safety Policy
- Identify if the H&S policy of the company also includes contractors
(policy applies to not only company employees but also
contractors)
- Ensure that the H&S policy is the internal H&S policy of the company
(not the company’s H&S policy for suppliers/business
partners/customers/consumers/etc.)
- Scoring
o Yes - the company’s policy must be followed by contractors
as well
o No - the company explicitly stated that the H&S policy is not
followed by contractors or they stated that the scope covers
only their employees
o Not Disclosed - no evidence
H&S policy is enforced with auditing

• Definition: This data point refers to the existence of audits in the
company’s H&S policy
(a) Yes
(b) No
(c) Not Disclosed
• Keyword(s):
Monitoring, reviewing, auditing, audit, review, monitor, investigate, inspect,
inspection, H&S policy, Health & Safety Policy, Health and Safety Policy
- Identify if the company’s H&S policy is being monitored. This must
be on conducting audits/checks/reviews/monitoring to ensure
compliance of employees and those who must follow the policy
and it should not be for reviewing the policies only
o Monitoring, checking, auditing compliance of employees
- Scoring
o Yes - the company’s H&S policy is audited to ensure the
compliance of employees and those who should follow the
policy; use this score if company has ISO 45001/OHSAS
18001 certification for 100% of their operations (ensure that
company is explicitly certified)
o No - the company explicitly mentioned that the H&S policy
is not audited
o Not Disclosed - no evidence found
China A
100% of its operations, credit Yes.
Practices - Governance and Strategy - What executive body is

responsible for H&S strategy and performance?
H&S strategy and performance is managed by CEO
• Definition: This data point refers whether the responsibility of the
company’s H&S strategy and performance lies on the CEO
(a) Yes
(b) No
(c) Not Disclosed
• Keyword(s):
Chief Executive Officer, CEO, H&S policy, Health & Safety Policy, Health and
Safety Policy
- Score this datapoint if there is a direct CEO oversight. It could be

that the CEO itself is on top if H&S issues or a member of a
committee overseeing H&S issues (should be explicitly mentioned).
- Scoring
o Yes - the company’s H&S performance/strategy is managed
by CEO
o No - company stated that the H&S performance/strategy is
NOT managed by CEO
H&S strategy and performance is managed by Senior Executive or

Executive Committee
company’s H&S strategy and performance lies on the Senior Executive/s
or Executive Committee
(a) Yes
(b) No
(c) Not Disclosed
• Keyword(s):
Executive Officer, Executive, Senior Executive, H&S policy, Health & Safety
Policy, Health and Safety Policy
- Score the datapoint if a committee of composed of senior
executives (other than the CEO) are overseeing H&S issues. Distinct
committee under the Board - possibly Audit Committee is
applicable if EHS issues are explicitly mentioned in Audit
Committee Charter
- Scoring
by Senior Executives/Executive Committee
NOT managed by Senior Executives/Executive Committee
H&S strategy and performance is managed by Sustainability Committee,

H&S task force or risk officer
company’s H&S strategy and performance lies on the Sustainability
Committee, H&S task force or risk officer
(a) Yes
(b) No
(c) Not Disclosed
• Keyword(s):
Sustainability Committee, Health & Safety team, Health & Safety
Committee, Health & Safety officer, Risk officer, Health and Safety team,
Health and Safety team, Health and Safety officer, H&S policy, Health &
Safety Policy, Health and Safety Policy, HSE Committee, HSE officer, HSE
team
- Scoring
by a H&S task force or risk officers
NOT managed by a H&S task force or risk officers
JP IMI
- Sub-Industry: All
- Source: https://elaws.e-
gov.go.jp/document?lawid=347AC0000000057
H&S strategy and performance is managed by an executive body Commented [SAM60]: For now: same definition and
• Definition: This data point refers whether the responsibility of the guidance for CEO and Senior/Executive Committee
datapoints; follow current validation rules
company’s H&S strategy and performance lies on the executives
• Dropdown choices: Commented [ACJ61]: Pending to Content:
(a) Yes To be discussed internally within the content team for
(b) No possible changes/updates on guidance of the
(c) Not Disclosed datapoint
• Keyword(s):
Executive, H&S policy, Health & Safety Policy, Health and Safety Policy
- Score this datapoint if an executive (other than CEO or senior
executive committee or board audit committee) has oversight of
H&S issues
- Scoring
by an executive body

NOT managed by an executive body
Practices - Targets
Programs to support its Health & Safety targets
• Definition: This data point refers to the initiatives/programs the company
have so they can achieve their Health & Safety targets
(a) Third-party assessment supported by analytical evaluation of key
risks across all operations
(b) Internal assessments and Health & Safety targets for selected high
risk operations
(c) General statements on having Health & Safety targets
(d) No evidence
• Keyword(s):
Health and Safety target, Health & Safety target, Health & Safety
assessment, target assessment, reduce TRIR, reduce LTIR, reduce
accident, reduce death, reduce fatality, reduce fatalities, mock drill,
emergency drill, safety inspection, safety program, fire drill
- Identify if the company has some initiatives/programs the
company have that they should do to achieve the H&S targets
- Scoring
o Third-party assessment supported by analytical evaluation
of key risks across all operations - company has
assessments on their H&S performance/strategy risks for
all operations for their targets; third-party (external
assessments) must be present to score this data point
o Internal assessments and Health & Safety targets for
selected high risk operations - company has assessments
on their H&S performance/strategy risks for some of their
operations for their targets; internal assessments only
o General statements on having Health & Safety targets -
company only has statements/mentioned that they have
H&S targets, or they have general statements that they aim
to achieve their targets with no supporting details
o No evidence - no disclosure found
Target to improve H&S performance

• Definition: This data point refers to whether the company has a
target on H&S performance
(a) Non-zero target (contractors included)
(b) There is some evidence the company has targets
(c) Non-zero target (contractors not included)
(d) Zero target
(e) No target
• Keyword(s):
Zero death, zero accident, zero fatalities, zero, health and safety target,
health & safety target, reduce TRIR, reduce LTIR, reduce accident, reduce
death, reduce fatality, reduce fatalities
- Identify if the company has targets on H&S performance
- Scoring
o Non-zero target (contractors included) - company has a
target (not a zero target), and contractors are included;
ensure that there is clear/explicit evidence that contractors
are included in their H&S target or if the company also has
targets set for contractors
o There is some evidence the company has targets – this
score is not used. Avoid using this score.
o Non-zero target (contractors not included) = company has
a target (not a zero target), and contractors are not included;
if there is no clear evidence that contractors are
included/not mentioned, use this score
o Zero target - company has a target that aim for zero
(accidents, fatalities, LTIR, TRIR, etc.)
o No target - no evidence or no targets disclosed
Practices – Targets - What reduction in H&S incidents is the

company targeting to achieve by or in the following years?
Baseline Year (YYYY)
• Definition: This data point refers to the year the company’s H&S target will
be based on/compared to
N/A – input value
• Keyword(s):
- Targets table should be scored if there is a quantitative/numerical
target, Target Reduction, and two or more of the following
identifiers: Baseline Year, Baseline Value, Target Year, Target
Reduction (%)
- Place in baseline year of the target
o Baseline year is the year the company’s target will be
compared to, to see if there are achievements in
reduction/improvement
Baseline
• Definition: This data point refers to the value the company’s H&S target will
be based on/compared to
N/A – input value
• Keyword(s):
Reduction (%)
- Place in baseline value of the target
o Baseline value is the value the company’s target will be
compared to, to see if there are achievements in
reduction/improvement
Target Year (YYYY)
• Definition: This data point refers to the year the company wants to achieve
their H&S target
N/A – input value
• Keyword(s):
Reduction (%)
- Place in target year of the target
o Target year is the year the company’s aims to have their
target achieved
Target Description
• Definition: This data point refers to additional details on the company’s
H&S target
N/A – free text
• Keyword(s):
Reduction (%)
- Place in description of the target
Target Reduction (%)

• Definition: This data point refers to the target of the company on H&S
performance (percentage target reduction)
N/A – input value
• Keyword(s):
Reduction (%)
- Place in percentage reduction of the target
o It is the percentage of the reduction of a certain H&S metric

compared to their baseline value
• E.g. Target is to reduce LTIR by 50% in 2030 (target
value: 0.25 per million hours) from 2015 LTIR
baseline (value: 0.5 per million hours).
Executive body responsible for Health & Safety Practices
• Definition: This data point refers to the responsibility of the executives on
Health & Safety practices of the company
(e) No evidence
• Keyword(s):
Health & Safety, Health and Safety, H&S, Health and Safety team, Health &
Safety team, EHS team, EHS officer, Risk officer, CSR team, CSR
committee, Sustainability committee, Sustainability officer, CEO, Chief
Executive Officer, H&S officer, Health & Safety officer, HSE Committee, HSE
officer, HSE team
- C-suite/Executive committee/Board-level committee should only
be given when there is clear evidence of their involvement in
managing Health & Safety or being directly responsible on the
company’s H&S practices (not just based on a mere mention of
board members or executive officers).
- Scoring
o Board-level committee - score if the committee involving
the board of directors/a board committee is responsible for
H&S practices of the company
o C-suite or Executive committee - score if a committee
involving the C-suite executives committee or any C-suite
executive (those with Chief titles) is responsible for H&S
practices of the company
o Special task force or risk officer - score if a dedicated H&S
team or risk officer is responsible for H&S practices of the
company (not the CSR/Sustainability/ESG team)
o Corporate Social Responsibility/ Sustainability team -
score if the CSR team, ESG team, Sustainability team is
responsible for all ESG/Sustainability/CSR practices of the

company (ensure that Health & Safety are also included)
o No evidence - no disclosure
China A
- Default Scoring: Special task force or risk officer as default if there
is no evidence
- Sub-Industry: All sub GICS industries under Metals and Mining
and Chemicals
- Source: According to Safety Production Law of PRC, Chapter 1,
Article 5, “the main person in charge of the production and business
operation shall be taking the full responsibility of safety production.”
In addition, the Order of the State Administration of Safety
Production define the main person as, “the main person in charge of
production and business operation refers to the chairman and/or
general manager of a limited liability company or a joint stock limited
company.”
Monitoring Health & Safety performance on leading indicators (near

misses, % of workers trained on Health & Safety, etc.)
• Definition: This data point refers to the company’s way of monitoring their
H&S performance
(a) Monitoring based on tracking quantitative Health & Safety metrics
(b) Monitoring based on conducting qualitative Health & Safety
assessment
(c) No evidence
• Keyword(s):
Health & Safety, H&S, Health and Safety, TRIR, Total Recordable Injury Rate,
Total Recordable Incident Rate, LTIR, Lost Time Incident Rate, Lost Time
Injury Rate, Lost Time, Lost-Time, Fatal, Death, Fatalities, Accident, Health
& Safety performance, Health and Safety performance, H&S performance
- Identify how the company monitors their Health & Safety performance
- Qualitative vs quantitative
o Quantitative monitoring is when the company reports health
and safety performance with quantitative/numerical data
o Qualitative monitoring is when the company mentioned it
monitors or tracks health and safety performance but has
not disclosed quantitative data; if the company only reports
qualitative performance (e.g. low fatality) but no numeric
value reported.
- Scoring:
o Monitoring based on tracking quantitative Health & Safety
metrics = score if the company monitors their H&S
performance via quantitative data (LTIR, TRIR, Fatalities,
Other H&S Metrics etc.); you may score this when the
company has numeric H&S data (ensure that those data are
also placed in the respective Performance tables)
o Monitoring based on conducting qualitative Health &
Safety assessment = score if the company monitors their
H&S performance by qualitative means
o No evidence = score if there is no evidence that the
company monitors their H&S performance
Management of Health & Safety Performance

• Definition: This data point refers to the company’s management on Health
& Safety performance
(a) Centralized Health & Safety management
(b) Decentralized Health & Safety management
(c) General statements on Health & Safety management
(d) No evidence
• Keyword(s):
subsidiaries, group-wide, ISO 45001, ISO45001, OHSAS 18001, Commented [ACJ62]: Content to send additional
OHSAS18001 possible keywords for this datapoint
- Identify the kind of management the company has regarding their
H&S performance (officer, committee, executives, etc.) and the
management directly responsible for H&S performance of the
company
- Check H&S websites of subsidiaries to determine if there are
decentralized H&S management
- Scoring:
o Centralized Health & Safety management = the company
has only one management that handles/is responsible for
all the H&S performance of the company (including all
subsidiaries, joint ventures, etc.)
o Decentralized Health & Safety management = the company
has multiple managements across all geographic locations
where the company operates that handle a particular
operation’s H&S performance
General statements on Health & Safety management =

o
company only mentioned (with no further details) that they
have a management that monitors the company’s H&S
performance; company has a H&S management in place but
does not report the scope (i.e. unclear whether it is
centralized or decentralized).
o No evidence = no disclosure found
China A
- For China-based issuers, if the company has local certification GB/T
45001-2020 (or GB/T 28001-2011) for 100% of its operations, select
centralized; if the certification is only for some of its operations, then
select “Decentralized Health & Safety management”.
- China A default (General statements on Health & Safety management)
is discontinued.
Executive compensation linked to Health & Safety performance

• Definition: This data point refers to how the executive compensation on
Health & Safety performance is awarded to executives
(a) Compensation linked with improvements in Health & Safety
performance
(b) Compensation linked with maintaining current Health & Safety
performance
(c) No evidence
• Keyword(s):
compensation, Health & Safety incentive, Health & Safety bonus, Health
and Safety incentive, Health and Safety bonus, H&S incentive, H&S bonus,
Health and Safety, H&S, Health & Safety, long-term award, short-term
award. long term award, short term award, ESG criteria, Safety criteria, H&S
criteria, H&S metrics, Safety metrics
• General Procedure: Commented [SAM63]: Pending to Content:
- H&S compensation criteria are usually found in their Short-term
In cases where disclosures on executive compensation
incentive plan (STI) or Long-term incentive plan (LTI) are general (e.g. no quantifiable H&S compensation
- Can also be found as a general statement in their CSR/AR metrics), which score should be used?
- This must be for executives and not employees.
-To be discussed by content with China market
- Scoring:
experts
o Compensation linked with improvements in Health &
Safety performance - score if the company’s executive
compensation will be higher if there are increasing
improvements in their H&S performance for the year based

on their H&S criteria
o Compensation linked with maintaining current Health &
Safety performance - score if the company’s executive
compensation will be higher if they can maintain their
current H&S performance for the year based on their H&S
criteria
o No evidence - no disclosure found
Health & Safety standards for contractors

• Definition: This data point refers to the applicability of H&S standards,
metrics, and policies on contractors
(a) Health & Safety standards and reporting for contractors equal to
permanent employees enforced with auditing
(b) Health & Safety standards and reporting for contractors equal to
permanent employees, not supported by auditing
(c) Overarching Health & Safety policy and contractors are included in
Health & Safety metrics
(d) Reports contractors in Health & Safety metrics
(e) General statements on having Health & Safety standards for
contractors
(f) No evidence
• Keyword(s):
Health & Safety policy, H&S policy, Health and Safety policy, contractor
- Scoring:
o Health & Safety standards and reporting for contractors
equal to permanent employees enforced with auditing = the
company’s H&S standards and reporting
processes/procedures are the same with the company’s
permanent employees AND there are audits conducted on
contractors to ensure compliance with the
standards/reporting procedures
o Health & Safety standards and reporting for contractors
equal to permanent employees, not supported by auditing
= the company’s H&S standards and reporting
processes/procedures are the same with the company’s
permanent employees BUT not enforced with auditing
o Overarching Health & Safety policy and contractors are
included in Health & Safety metrics = H&S standards/policy
apply to or cover contractors AND contractors' safety
metrics data are reported by the company BUT reporting

processes/procedures are different with the company’s
employee H&S reporting
o Reports contractors in Health & Safety metrics = the
company discloses H&S metrics data for contractors
o General statements on having Health & Safety standards
for contractors = the company only has statements that
contractors follow certain H&S standards by the company
Practices - Operations - Regular audits of Health & Safety policy

and performance
Regular audits of Health & Safety policy and performance
• Definition: This data point refers to the extent of audits on the Health &
Safety policy and performance of the company
(a) Audits of all operations at least once every three years
(b) Audits of selected operations at least once every three years
(c) Evidence of audits but no specific details / Audits conducted but not
on a regular schedule
(d) No evidence
• Keyword(s):
ISO45001, Health & Safety audit, Health and Safety audit, H&S audit, site
inspection, H&S certification, Health & Safety certification, Health and
Safety certification
- This is the parent data point of “Scope of audits on health and
safety policy and performance” and “Frequency of Health & Safety
policy and performance audits”
- Identify if the company conducts audits on their H&S related
issues/performance/policy
o Monitoring/checking/reviewing performance and policy of
the company
- If company has ISO 45001/OHSAS 18001 certification, audits are
conducted every three years and is valid for this data point
- Scoring:
o Audits of all operations at least once every three years = all
operations are audited at least once every three years; ISO
45001/OHSAS 18001 certified companies fall under this if

they explicitly mentioned all operations are audited or
certified
o Audits of selected operations at least once every three
years = only selected operations are audited at least once
every three years; use this score if the company mentions
specific sites (but not all sites) have audits on H&S; ISO
45001/OHSAS 18001 certified companies may fall under
this if they did not mention all operations are audited or
certified, but they stated some site/locations that are
certified or they did not state the scope of their certification
but it is clear that they are ISO and/or OHSAS certified
o Evidence of audits but no specific details / Audits
conducted but not on a regular schedule = there is only a
general statement that the company’s operations having
audits on H&S or if they conduct audits but no further details
on the site/operations audited, locations audited, frequency
of audits, etc.
China A
100% of its operations, select audits of all operations at
least once every three years; if the certification is only for
some of its operations, then select “Audits of selected
operations at least once every three years”.
Scope of audits on health and safety policy and performance

• Definition: This data point refers to the scope/coverage of the audits being
conducted on the company’s health & safety policy and performance
(a) All or 100%
(b) Greater than 50%
(c) More than 25% and less than 50%
(d) Up to 25%
(e) Evidence of audits, but scope is not clear
(f) No evidence of audits
• Keyword(s):

- Identify the scope of company conducts audits on their H&S related
issues/performance/policy
o Monitoring/checking/reviewing performance and policy of
the company
- If company has ISO 45001/OHSAS 18001 certification, audits are
conducted every three years and is valid for this data point
- Scoring:
o All or 100% = all sites across all operations are audited
o Greater than 50% = majority of all sites across all operations
are audited
o More than 25% and less than 50% = most of the sites across
all operations are audited
o Up to 25% = a few sites across all operations are audited
o Evidence of audits, but scope is not clear = company
mentioned audits, but the scope is not determined; if the
company only stated the names of locations/operations
where audits are conducted but percentage cannot be
calculated/identified;
• use this score if the company is ISO 45001 and/or
OHSAS 18001 certified (explicitly) but there are no
clear statements on the scope of their certification.
o No evidence of audits = the company has no audits on H&S
China A
o For China-based issuers, certification GB/T 45001-2020 (or
GB/T 28001-2011) implies audits are conducted every
three years.
Frequency of Health & Safety policy and performance audits

• Definition: This data point refers to the frequency of audits being
conducted on the company’s health & safety policy and performance
(a) Yearly
(b) Biennial
(c) Triennial
(d) Semi-annual
(e) Quarterly
(f) Monthly
(g) Evidence of audits, but frequency is not clear
• Keyword(s):
- Identify how often the H&S audits are conducted
- If there are no H&S audits, use No Value
- Scoring:
o Yearly = annually, every year
o Biennial = every other year/two years
o Triennial = three times a year; use this score if the company
is explicitly certified to ISO 45001 or OHSAS 18001 and
there are no explicit statements on the frequency of their
Health and Safety audits. If there are explicit statements on
the frequency of their ISO 45001/OHSAS 18001, use the
appropriate score as disclosed instead
o Semi-annual = two times a year
o Quarterly = every quarter, every 3 months, 3 times a year
o Monthly= every month
o Evidence of audits, but frequency is not clear = there are
audits mentioned but frequency is not stated or does not fall
in any dropdown scorings above
China A
certification GB/T 45001-2020 (or GB/T 28001-2011) and
there are no explicit statements on the frequency of their
H&S audits, then select “Triennial”.
Practices - Operations - Membership / Signatory/ Certification

– Health & Safety Certification Standards
General Guidance for Membership / Signatory/ Certification – Health &
Safety Certification Standards
• Only add rows if there is evidence found. Delete blank published rows if there
is no disclosure
Estimated percent of operations certified to Health & Safety Standards

operations/health & safety systems that are certified to Health & Safety
standards
N/A – input value
• Keyword(s):
ISO45001, H&S certification, Health & Safety certification, Health and
- Place the estimated percentage of company operations that are
certified with H&S certifications
issuers)
o If the company’s H&S certification is that of ISO 45001 or
OHSAS 18001 and percentage was used in Percentage of
the company's health & safety system certified to OHSAS
18001 datapoint, you may use the same value here
List of Health & Safety certification standards

• Definition: This data point refers to the Health & Safety standards that the
company is certified to
N/A – free text
• Keyword(s):

ISO45001, H&S certification, Health & Safety certification, Health and
- List the percentage of H&S certification by the company
issuers)
- If the company has no certifications, leave this data point blank
Human Capital Development

This issue evaluates companies’ ability to attract, retain and develop human capital.
Scores are based on reliance on highly skilled or highly trained workers and exposure
to recent restructuring events; strategy and programs related to employee
engagement, training and development and benefits; employee turnover trend and
vs. peers; and workplace controversies.
Sources:
• Annual Report/10K • Diversity & Inclusion Policy
• ESG/Sustainability/CSR report • Human Rights Policy
• Company Website • Whistleblower Policy
Practices
Scope of support for degree programs and certifications Commented [LRA64]: Japanese companies undergo
• Definition: This data point refers to the scope of support for degree certification part of the Job will not consider here.
Company will have programs.
programs and certifications wherein company gives educational
assistance to the employees. Content Team to provide example.
(a) Programs covering all employees (including part-time and contractors)
(b) Programs covering all permanent employees (excluding part-time and
contractors)
(c) General statements on training and development
(d) No evidence
• Keyword(s):
degree program, certifications, university, tuition reimbursement, monetary

support, financial assistance, financial support
- We want to look for the hints in compensation and benefits regarding
tuition reimbursement or financial assistance for higher education or
professional certification.
o Note: For the certification, avoid confusion that pertains a
required certification on employees that are necessary for
doing the job.
- Examples: Commented [LRA65]: Pending with Content Team:
o Cloud Computing can be considered in Technology Industry Provide list of reference for each sector.
o Develop customized training certificate programs like from Example:
Amazon and Microsoft. IT: Cloud computing
- We can credit on this datapoint if there are companies have employee
sponsorship programs on their owned establish universities.
- Reminder: This should focus on employee development sponsored by
the company.
- Scoring:
o Programs covering all employees (including part-time and
contractors) - If a company explicitly mentions that it supports
degree programs and certifications for all its employees
(including part-time and contractors) we give it the top credit.
o Programs covering all permanent employees (excluding part-
time and contractors) - If a company explicitly mentions that
it supports degree programs and certifications for FTEs or
permanent employees without mention for contractors, we
give it the specified credit.
o General statements on training and development - If the
company have a program on supporting degree programs and
certifications for employees but doesn’t specifically mention
the scope, we give this credit.
o No evidence - we give it the least credit if none of the above-
mentioned disclosures are provided by the company.
JP IMI
- Specific Guidance: Companies tend to disclose information related to
training programs on the career page of their website. Normally in Japan,
company’s career websites are targeting new graduates.
Workforce diversity policy and management oversight

• Definition: This data point provides information on workforce diversity
policy and management oversight
(a) Employee training on diversity policy, supported by senior executive or
higher level of oversight on diversity performance
(b) Senior executive or higher level of oversight on diversity performance
(c) Employee training on diversity policy
(d) General statements on diversity and equal opportunity
(e) No evidence
• Keyword(s):
'diversity', 'inclusion'
Equal recruitment (平等就业), Diversity (多样性), inclusion (兼容)，minority
ethnics (少数群体); anti-discrimination (反歧视)
- Scoring:
o Employee training on diversity policy, supported by senior
executive or higher level of oversight on diversity
performance - We are looking for the company’s Diversity
and Inclusion committee or cell chaired by the senior
executives or higher management. The company should
have detailed diversity policy regardless personal
differences (e.g., Gender, nationality, work history, age,
sexual orientation, etc.) Classroom and/or online trainings
should be provided to employees (FTE and contractors) on
diversity parameters - on equal opportunities, women
empowerment, local employment opportunities,
employment opportunities for the disabled group etc. Also,
the company might mention details on diversity targets like
Disability Inclusion, Balancing Gender, etc. and mechanism
to achieve them.
o Senior executive or higher level of oversight on diversity
performance - If Diversity and Inclusion committee or cell
established within the company oversighted by the senior
executives or higher management with details on diversity
and equal opportunities targets and mechanism to achieve
them. (Special case: If any company mentions about the
various diversity programs carried out for its employees but
doesn’t mention about the supervising committee, we still
maintain this credit for the company.
Employee training on diversity policy - details on

o
classroom and/or online trainings provided to employees
(Permanent and contractors) on diversity parameters.
These trainings can be mandatory or voluntary, internal, or
external based on the materiality issues for the company.
o General statements on diversity and equal opportunity – If
a company does not mention details on the D&I committee
or Employee Resource Group (ERG), targets or trainings but
simply mentions general statements on diversity and equal
opportunity we select on this credit.
o No evidence - we give it the least credit if none of the above-
mentioned disclosures are provided by the company.
China A
- Default Scoring: General statements on diversity and equal opportunity
- Source: Labor Law of the People's Republic of China No.12 There
shouldn't be any discrimination because of nationality, race, sex, and
religious belief. http://www.gov.cn/banshi/2005-
- Best Practice for the highest scoring: Employee training on diversity

policy, supported by senior executive or higher level of oversight on
diversity performance
o DO NOT give highest credit if found no standalone diversity
policy + explicit evidence of training on these topics +
management oversight
Programs to increase workforce diversity

• Definition: This data point provides information on company's programs to
increase workforce diversity
(a) Provides material benefits to facilitate diversity and inclusion, and sets
quantitative diversity targets in recruitment process
(b) Provides material benefits to facilitate diversity and inclusion
(c) Quantitative diversity targets in recruitment process
(d) General statements on plans to improve diversity in workforce
(e) No evidence
• Keyword(s):
'diversity', 'inclusion'
Equal recruitment (平等就业); discrimination (歧视)
- We could check companies’ website “Career page” regarding

recruitment initiatives that help increase diversity.
- Scoring:
o Provides material benefits to facilitate diversity and
inclusion and sets quantitative diversity targets in
recruitment process – If a company mentions about the
explicit material benefits to employees in addition to
recruitment targets like empowering women, regional
recruits, local employment targets, nationality specific
employment, etc. we give the company topmost credit.
These targets can be short term or long term wherein the
company updates on its achievement status.
o Provides material benefits to facilitate diversity and
inclusion – When a company mentions details on the
material benefits provided to employees but does not
specify on any targets set or achieved, we select this credit.
o Quantitative diversity targets in recruitment process –
When a company mentions details on the target set (e.g.,
percentage or year goal) to achieve on any diversity targets,
we give this credit.
• Note: Employees, leadership / managers are
acknowledged but not the Board of Directors.
o General statements on plans to improve diversity in
workforce – When the company does not mention any
details on material benefits or recruitment targets and
mentions just general statements on diversity enhancement
plan or vague targets like increase in diversity, we select this
credit.
• Different approach/ examples: If the evidence
offers parental benefits to increase workforce
diversity. The takeaway here is we must refer on
each market mandated benefit whether offers
beyond mandated benefit by government. Please
keep this as “General Statement”.
o No evidence – we give it the least credit if none of the
above-mentioned disclosures are provided by the company.

China A
- Best Practice for the highest scoring: Provides material benefits to

facilitate diversity and inclusion, and sets quantitative diversity targets
in recruitment process
o if there are explicit disclosures in terms of recruitment - that
binds with the diversity and inclusion programs.
o Note:
• Look for evidence of explicit quantitative target for
recruiting female employees, minor ethnic
employees, or disabled employees.
• Material benefits should at least include benefits for
supporting female employees return to work after
maternity leaves
Strategy
Extent of grievance reporting or escalation procedures
• Definition: This data point provides information on extent grievance
reporting or escalation procedures of the company for the employees to
report issues or complaints.
(a) Formal grievance escalation/reporting (confidential)
(b) Formal grievance escalation/reporting (not confidential or
confidentiality unknown)
(c) Company offers internal employee council / committee but grievance
procedures unknown
(d) No evidence
• Keyword(s):
''grievance', 'escalation', harassment, complaints, discrimination
- This data indicator is about the measures/ programs/ panels/
platforms for employees to voice their concerns or raise complaints
about employment grievance through the Whistleblower Channels
setup by the company
o Employee grievances include employee-related (e.g.,
discrimination, harassment, and other employment issues)
issues/complaints that are outside reporting misconduct,
so as not to confuse with Corporate Behavior whistleblower
reporting.
o Look for whistle-blower policies for employee grievances
specifically and NOT for violation of code of ethics/anti-
bribery/anti-corruption.
- Remember to consider employee representatives (which are different

from trade union representatives), and employee grievance councils,
which can be mandatory in many developed markets above a certain
number of employees (20, 50, or 100)
- Scoring:
o Formal grievance escalation/reporting (confidential) - if
there are formal anonymous system with a legal protection
for employee grievance system.
o Formal grievance escalation/reporting (not confidential or
confidentiality unknown) - if there are formal anonymous
system without indicating legal protection for employee
grievance system.
o Company offers internal employee council / committee but
grievance procedures unknown - if there are general
statement on available (internal) channels for grievance
reporting related to employee complaints/matters.
• Example of internal channels may include
references to reporting to skip level managers or HR
partners or General Counsel or Legal/Compliance
officers
Talent pipeline development strategy

Formal talent pipeline development strategy (forecasts hiring needs,
actively develops new pools of talent)
• Definition: This data point provides information on strategies, policies, and
mechanism on recruitment part by prospecting new joiners and pooling on
a new talent who they would eventually hire.
(a) Yes
(b) No
(c) Not Disclosed
• Keyword(s):
''training', 'talent development', 'skill development'
- Most be a company-wide strategy backed by quantitative metrics
- Scoring:
o Yes – the company states on having a strategies or plan
for forecasting hiring needs or pooling on new talents.
•Companies also consider partnership with

accredited universities or technical schools to look
for their new talents or qualification needs.
o Not Disclosed - if no information found.
Graduate traineeship/apprenticeship program

• Definition: This data point provides information on company's graduate
traineeship/apprenticeship program
(a) Yes
(b) No
(c) Not Disclosed
• Keyword(s):
''training', 'graduate intern', 'apprenticeship', internship
- There are some companies are not directly disclosing on their reports.
Hence, we can also google: “Company name +
internship/apprenticeship” to see job listings.
- Scoring:
o Yes - Identify if company offers internship, apprenticeships,
or graduate programs.
• Guidelines for Specific Industry / Market Commented [LRA66]: @Atilano, Cristine Joyce
China A
- Simple internship should not be considered, only the programs that
cultivate future talent pool for the company could be considered ”yes”
here
- Note: look for evidence of training programs specified for
graduate/future leaders (career website/CSR. Example: “management
trainee”
Partners with educational institutions to develop or deliver joint training

programs for staff
• Definition: This data point refers to partners with educational institutions
to develop or deliver joint training programs for staff
(a) Yes
(b) No
(c) Not Disclosed
• Keyword(s):
'benefits', 'bonus', 'variable'

educational institutions 教育机构; universities 大学
- Increasing skills can be considered on this datapoint but for teaming
up with Research will not be considered.
- Scoring:
o Yes - if the company has formal engagement or academic
association with a university or college to conduct
professional training courses for its employees
• Please be noted: We cannot consider Universities
created by companies themselves.
• Guidelines for Specific Industry / Market Commented [LRA67]: Pending query with Content
China A Team. Please check the file in AdHoc Teams Channel
- Look into the “employee training” section of company’s annual for the whole question.
report/CSR report/website. If the company mentions names of 1. Real Estate Management Services and Financials
universities or schools, they are partnered with consider – yes. sector follow a threshold of +/- 2% of average, to
- The company should also disclosure information about the program, consider it “in line” with industry median. Would you
confirm if this threshold can be used in all sectors?
participants, budgets and other comprehensive details.
- Note: DO NOT account for “universities/institutions” which are an 2. Financial sector is considering the 3-year average.
internal training function and most of the trainers would be internal Kindly check the procedure in Guidelines for Specific
Industry / Market section.
employees.
Question: As of now, only financials sector follows this
Operations procedure. Should this be followed across all sectors? I
think it will be difficult if we have different procedures
Employee Turnover on every sector.
• Definition: This data point provides information on company's employee 3. If we are only getting turnover ratio for 1 year and it
turnover and determine the trend of annual employee turnover. is above or below the industry average, what should be
the scoring? There is a discussion regarding EMC
• Dropdown choices: approval on 2 additional options, 1) above industry
(a) Above industry average, increasing trend average, decreasing trend and 2) below industry
(b) On par with industry average average, increasing trend. But for this question, there’s
only one turnover ratio and it is insufficient to analyze
(c) On par with industry average, increasing trend
the trend. Can you confirm what should be the scoring
(d) On par with industry average, decreasing trend for such case?
(e) Below industry average, decreasing trend As per Research analyst, this can be not disclosed as
we cannot see the trend. But needs to be checked with
(f) No disclosure
other sectors so we have consistency on scoring a
• Keyword(s): binary performance indicator.
4. If we follow the procedure mentioned in #2, would
resign 离职; employee turnover rate 离职率 the content team provide the 3-year industry average
• General Procedure: every year?
- If there are a lot of disclosure on turnover, use the voluntary reported

turnover.
- Scoring:
o Above industry average, increasing trend – if the issuer is
above the industry median
o On par with industry average - If the issuer’s employee
turnover rate is within +/- 2% of average, we can say “in line”
with industry median.
o On par with industry average, increasing trend – if the issuer
turnover rate is increasing compare on previous year but still
within the industry average
o On par with industry average, decreasing trend - if the issuer
turnover rate is decreasing compare on previous year but still
within the industry average
o Below industry average, decreasing trend - if the issuer
turnover rate is below the industry average

Industry Guidelines
- Sector: Financial
- Above, on par, or below industry average: We should look at the 3-
year average ratio for the company (e.g., 2018-2020) and compare
to the industry 3-year average. If we do not have data available to
calculate the 3-year average, then we should do average for the
data we have available.
- On par: Use +/-2 as threshold
o If in a case where only voluntary turnovers are mentioned -
consistently lower than three years industry average. In that
scenario - score should be "on par".
- Increasing or decreasing trend: We should think of the trend as
being more than just a one-year change as we are looking at the 3-
year average turnover ratio. For example, if the trend for last several
years has been increasing but then in 2020 there is a slightly dip
until we have more than 1 year of decrease, we cannot say that it is
a decreasing trend.
- For Supranationals, please compare with 3-year average of banks.
Sector 2020 3-Year Average

Financials 11.37
GICS Group 2020 3-Year Average

Banks 10.74
Capital Markets 10.42
Consumer Finance 21.71

Diversified Financials 10.34
Insurance 12.92
Mortgage REITs 9.92
GICS Sub Industry 2020 3-Year Average

Asset Management & Custody Banks 9.67
Diversified Banks 10.89
Diversified Capital Markets 9.31
Financial Exchanges & Data 10.69
Insurance Brokers 8.3
Investment Banking and Brokerage 11.39
Life & Health Insurance 14.91
Multi-Line Insurance 11.53
Multi-Sector Holdings 11.59
Other Diversified Financial Services 9.86
Property & Casualty Insurance 11.35
Regional Banks 9.72
Reinsurance 9.13
Specialized Finance 9.86
Thrift & Mortgage Finance 10
- Sub-Industry: Real Estate Management Services (REMS)

- Current Industry Average: 14.9%
o If the issuer’s employee turnover rate is within +/- 2% of
average, we can say “in line” with industry median. (12.9% -
16.9%).
o Please mark the ‘Employee turnover’ indicator under HCD
as ‘No Value’ for companies with 80 or less employees.
▪ Reason: Companies with low employee base tend
to exhibit extreme fluctuations in their employee
turnover rate resulting in fluctuations in the
‘Employee turnover’ indicator. This indicator carries
significant weight in the HCD KI causing huge
rating volatility which may not be based in real
change in performance or policies. To reduce
volatility, we can leave the ‘Employee turnover’
indicator as blank for companies with low
employee base. Low employee base: To determine
the cutoff of 80 employees, we had a look at the
workforce data for REMS, took the bottom
minorized quartile, and added a 10% buffer to avoid
regular calibration as quartiles move each year.
o Externally managed issuers typically do not have their own

employees and rely on an external manager for their
human capital needs. In this case, we consider the external
manager’s HCD practices when rating the issuer
o In terms of HCD metrics such as workforce size, turnover
rate, etc., we first must check if the external manager
manages other entities aside from the issuer that we are
rating. If we can confirm that the external manager is
managing only that one specific issuer and no other
company, then we can consider the external manager’s
disclosure on metrics such as workforce size, employee
turnover, etc. when rating the issuer. We can then check
the applicability of below rule by looking at the workforce
size disclosed by the external manager.
o For example, issuer ABC is externally managed by
Manager. Manager does not manage any other company
and is only solely focused on issuer ABC.
▪ If Manager’s workforce size is 80 or less, ‘Employee
turnover’ indicator for issuer ABC should be ‘No
Value’.
▪ If Manager’s workforce size is greater than 80, we
must score ‘Employee turnover’ indicator
accordingly. If there is no information on turnover
rates, then we score it as ‘No disclosure’.
o Another example, issuer ABC is externally managed by
Manager, but Manager oversees human capital needs of
two other entities.
▪ If the Manager discloses granular information, such
as workforce size and turnover rates per entity that
it manages, then we consider only the data
pertaining to issuer ABC. For example, according to
Manager, it has X number of employees dedicated
to issuer ABC and ABC’s turnover rate for the year
is Y%. We can then check the applicability of the
rule and score accordingly.
Programs & Initiatives

Availability of variable component to pay for non-officer and non-sales
staff
• Definition: This data point provides information on availability of variable
component to pay for non-officer and non-sales staff
(a) Yes
(b) Not Disclosed

• Keyword(s):
'benefits', 'bonus', 'variable’, ‘incentives’
Performance （业绩/绩效）; bonus (奖金);
- There are some of the companies mention incentive plans as well
which award cash bonus to all its employees apart from shared based
plan. Or we could also check the non-cash incentives like RSU’s
(Restricted Stock Units) offered to non-officer staff.
- Scoring:
o Yes - if the company has variable component to pay for non-
officer and non-sales staff

China A
- Disclosure of data regarding eligibility of variable compensation
Regular performance appraisals and feedback processes

• Definition: This data point provides information on regular performance
appraisals and feedback processes of the company
(a) Sector leading programs
(b) Yes
(c) No
(d) Not disclosed
• Keyword(s):
'review', 'feedback', 'performance',’360 appraisal process’
Annual Performance Appraisal 年度绩效评估;
- Default Scoring:
o Yes – Financial Industry
- Scoring:
o Sector leading programs – this would be based on the
warrant regular (semiannual) performance reviews, with
goal setting, detailed career and training plans created
accordingly, and performance-based compensation.
o Yes – if there is a disclosure giving a regular performance
appraisals and feedback process
o Not disclosed – better to score ‘Not Disclose” than scoring

“No” if there is no evidence.

China A
- Sector leading programs - Disclosures of feedback process and
percentages of how many employees were subjected to it. For sector
leading we consider sector leading process like 360-degree feedback
and comprehensive assessment procedure described
- DO NOT give the highest-level credit for performance-based
bonus/variable pay only (must have evidence of feedback process).
- DO NOT account for “public announcement” or “external feedback”
specified for promoting key management personnel only (often seen
for SOEs)
Job-specific development training programs Commented [LRA68]: Pending query with Content
• Definition: This data point provides information on job-specific Team.
development training programs of the company 1. To differentiate and give samples for each option.
• Dropdown choices: a.Sector leading programs
(a) Sector leading programs b.Yes
(b) Yes
(c) No
(d) Not disclosed
• Keyword(s):
'training', 'talent development', 'skill development'
Job skill Training (职业技能培训), “talent” (人才) "develop" （发展）
- We could consider this development training programs such as
behavioral, communication or technical training and any kind of
associations or owned establish universities that provide programs or
development training.
- Scoring:
o Sector leading programs – Eligibility and value/scope of
training/details, generous combination of internal/external
training, tailored training and educational support.
o Yes – average training programs, some tuition reimbursement.
o Not disclosed – better to score ‘Not Disclose” than scoring
“No” if there is no evidence.
Industry Guidelines
- Sector: Financials
o Most Financial sector entities have policies on providing job-
specific trainings to employees. Hence analysts should at
most times score a "Yes" on this. A "Not Disclosed" or "No"
should be selected when there is explicit mention that the
entity does not provide job specific trainings.
China A
- Sector leading programs - explicit and comprehensive evidence for
one-on-one professional developmental dialogues or other specific
programs
Performance
External recognition as employer of choice (last three years)
• Definition: This data point provides information on External recognition as
employer of choice for the last three years.
(a) Recognized as top employer on credible external list
• Keyword(s):
''award', 'best employer'
- The credit should be given if the company fulfills the following criteria
for any of the last three years (counting backwards from the month when
the company is being assessed):
o Only give credit for independent, 3rd party assessments,
should not be company initiated (e.g., great place to work
certification).
• Credible external lists and rankings include
▪ Fortune’s 100 Best Companies to Work
▪ Forbes
o Only consider international awards - Forbes, Fortune and
GPTW - given at a country/ global level. No local
recognitions to be considered even from the international
awards.
• Examples:
▪ Forbes - #45 Best place to work in
Technology – Yes
▪ GPTW - #12 Best place to work in India- Yes
Fortune - #3 Best place to work in Bay Area-

▪
No
o Only consider awards from Forbes, Fortune and Great Place
to Work given for workplace as a whole and not for sub-
segment like for mothers, LGBTQ+, etc.
o Exclude government awards (linked to facilitation in some
markets like China) and Indexes.
- Scoring:
o Recognized as top employer on credible external list – This
scoring will be based on this interlinked data point on Common
LM/HCD – Type of award.
Workforce Diversity
- Add a row for the latest fiscal year if there is total workforce data from
Total Workforce Composition table in Common LM/HCD. Do not add
rows in HCD if the total workforce is not yet updated by Exposure Team.
- For published rows with no equivalent row in Total Workforce
Composition in Common LM/HCD, do not delete row/s. Retain the
published data.
Annual employee turnover Commented [LRA69]: Under discussion with Research

• Definition: This data point refers to the annual employee turnover and Content.
expressed in percentage.
• Keyword(s):
- Note: Interlinked with the value from Common LM/HCD – Annual
Employee Turnover.
- Do not calculate employee turnover rate.
- If HCD is non weighted but the previous year has a published value,
continue to input the value.
- Important Guidelines: If historical year have input a value hence this
should be followed.
Profit per employee (USD '000)

• Definition: This data point refers to the profit per employee expressed in
thousand USD.
• Keyword(s):
'profit', 'net income'
- Need to calculate by searching for net profit for the most relevant year
and dividing it by the number of employees
- Formula: Net Profit/ Total Employees
- Net profit should be taken from the annual report.
- Note: Leave blank if there is no information but if one of the information
is missing then indicate the disclose value in Internal Notes.
- Important Guidelines: If historical year have input a value hence this
should be followed.
Number of women employees in workforce

• Definition: This data point refers to the number of women employees in
workforce
• Keyword(s):
'women', 'female'
- Identify the total number of women employees in workforce.
o Kindly compare if the company provided a percentage of
women in workforce. If yes, then use this formula to
compute “Total workforce * percentage of women in
workforce “
- NOTE: This datapoint relates to Total Workforce in Common LM/HCD.
(Total Workforce Composition table).
- But remember that there are times that Total Workforce in Common
LM/HCD only provides full-time employees. Hence, we need to check
for women employees of total workforce (full-time, part-time,
contractors, etc.)
- Please be reminded that the value should not be more than the Total
Workforce.
Number of women in executive management

• Definition: This data point refers to the number of women in executive
management
• Keyword(s):
'women', 'female', 'management', 'executive management'
- A Team of individuals at the highest level of management of an
organization. Job Titles such as Chief Operating Officer (COO), Chief
Executive Officer (CEO), Chief Financial Officer (CFO), President, Vice
President are commonly used by top managers in organizations.
- The Executive Committee is normally headed by the CEO or Chairman.

They are not the Board of Directors, but some Board members may be
part of Executive leadership
- Get the number of women in the executive management and enter in
this filled.
- NOTE: This datapoint relates to Total number of Executive
Management in Common LM/HCD (Total Workforce Composition
table). Please be reminded that the value should not be more than the
Total Executive Management.
•Guidelines for Specific Industry / Market

Japan
Japanese Executives
会長 kaichou


Names
China
Chinese Executives

董事长
监事 Supervisor
财务总监 CFO

This can’t be included however if the person has a

Gender (性别)

Number of women in senior management

senior management
• Keyword(s):
'women', 'female', 'management', 'senior management'
- A team of managers at senior positions who are responsible for
planning and directing the work of a group of individuals.
- When the company does not define executive team but states all under
heads like Management team, Officers, Supervisory team etc.
- Get the number of women in the senior management and enter in this
field.
- Additional Note for identifying senior management: If the company
identifies two tiers of top managers, e.g., an ‘executive committee’ or
‘senior leadership’ PLUS an additional larger set of people, put the first
group in “executive management” and the second ground in “senior
management”.
- NOTE: This datapoint relates to Total number of Senior Management in
Common LM/HCD (Total Workforce Composition table). Please be
reminded that the value should not be more than the Total Senior
Management.
•
Guidelines for Specific Industry / Market
Japan
Japanese Executives

会長 kaichou

Names
China
Chinese Executives

董事长

监事 Supervisor
财务总监 CFO
This can’t be included however if the person has a

Gender (性别)

Total number of newly hired employees

• Definition: This data point refers to the total number of newly hired
employees
• Keyword(s):
'new hires', 'new employees', 'recruit'
- Identify the total number of newly hired employees.
Number of women employees in new hires

new hires
• Keyword(s):
'new hires', 'new employees', 'recruit'
- Identify the total number of women employees in new hires. Please be
reminded that the value should not be more than the Total number of
newly hired employees
Average year employed by the company for female employees

• Definition: This data point refers to the average years employed by the
company for female employees
• Keyword(s):
'years of service’, ’men', 'male'
- Identify the average years employed by the company for female
employees. Commented [LRA70]: Pending query with Content
Team. Below query is available in Adhoc Teams
- Usually available in Japan and Korean issuers. Channel.
[Vendor Query]
Average year employed by the company for male employees These data points refer to diversity of ethnic minorities
• Definition: This data point refers to the average years employed by the in the company. As per common knowledge on the
company for male employees definition of minorities these are the underrepresented
races in a particular area (blacks, coloured, Africans,
• Keyword(s): Asians, etc.). However, for issuers based in countries
'years of service’, ’men', 'male' like South Africa, Asia, etc. where the considered
• General Procedure: minorities are greater, will the minorities be the
foreigners, whites, Americans, etc.? Are minorities
- Identify the average years employed by the company for male dependent on a country's Domicile?
employees.
- Usually available in Japan and Korean issuers. Example: Growthpoint (South African Company)
page 33/92 https://growthpoint.co.za/wp-
content/uploads/bsk-pdf-
Total number of ethnic minority employees in senior management manager/2021/10/Growthpoint-ESG-Report-2021.pdf
Employee Race %
• Definition: This data point refers to the total number of ethnic minority African 38%
employees in senior management Coloured 18%
• Keyword(s): Indian 8%
White 35%
'ethnic', 'minority', 'management' Foreign nationals 1%
- Provide the total number of ethnic minority employees from their senior
management team
Percentage of ethnic minority employees in senior management

• Definition: This data point refers to the percentage of ethnic minority
employees in senior management
• Keyword(s):
'ethnic', 'minority', 'management'
- Provide the percentage of ethnic minority employees in senior
management
- For Korean companies, it should be blank in most of the cases unless
we have clear evidence that the company has ethnic minority
employees (e.g., immigrants)
Total number of ethnic minority employees

• Definition: This data point refers to the total number of ethnic minority
employees
• Keyword(s):
'ethnic', 'minority'
- Provide the total count of ethnic minority employees
Percentage of ethnic minority employees in total workforce

• Definition: This data point refers to the percentage of ethnic minority
employees in total workforce
• Keyword(s):
'ethnic', 'minority'
- Provide the percentage of ethnic minority employees in total workforce
- For Korean companies, it should be blank in most of the cases unless
we have clear evidence that the company has ethnic minority
employees (e.g., immigrants)
Insuring Health Demographic Risk

This issue evaluates the extent to which companies may face insurance risks
associated with public health trends and demographic change. Scores are based on
exposure to product lines and geographies facing emerging health risks (e.g.,
obesity) or major demographic shifts, and integration of emerging risks into risk
management models and product strategy.
Changes in population dynamics, health issues, and other emerging risks are relevant
for insurance companies for both downside risk management and upside market
opportunity. Health and demographic risks can be very diverse in their type,
geographical scope, and timescales of operation.
Processes to identify and monitor risks may include dedicated emerging risk
identification procedures and committees, internal research functions, and
collaboration with external organizations in research. Mitigation implies that the
results of this research are translated into specific actions. These could include
changes to the company's strategy, changes in operational systems, and the
development of new products.
Practices
Comment on the company's structure and procedures in place to identify, monitor
and mitigate emerging risks.
• Definition: Describes company's structure and procedures in place to
identify, monitor and mitigate emerging risks
N/A - Short Text
• Keyword(s): Most likely, you will find this info under the risk management
section of the annual report.
- We are looking for the following:
o Company recognizes emerging risks
o Committee/Executive Body that monitors the emerging
risks
o Emerging risks are reported to the CSR Committee or Chief
Risk Officer
o Company states that product development, product pricing
and business strategy are linked to emerging risks.
Practices – The following emerging risks are listed as a

business risk factor:
We are looking if a specific issue is included in company’s business risks
assessment.
Assessment of business risks related to

▪ obesity and emerging health issues -The indicator is called “obesity and
emerging health”, but we are only looking at mention of “obesity” or
“overweight”. Emerging health issues should go to the emerging ESG issues.
▪ aging population and demographic change – look for information about
population mix is changing, increasing in the proportion of senior citizen, etc.
▪ urbanization trends – look for some high-level socioeconomic development
information Examples: rising income levels, improving savings, propel the
need in insurance coverage, etc.
▪ health impact of environmental changes – Examples: rising incident of
diseases due to change in temperature (i.e., higher temperature or humidity)
▪ emerging ESG issues – This is the “other” category. Anything health and
demographic risks that does not fall in the 4 categories above will be taken
into consideration in this datapoint including emerging health issue. Please
provide details in the below “detail” section.
▪ Other emerging risks – detail – provide the issues identified or included in
emerging ESG issues data point.
• Definition: Provides information on company’s assessment of business
risks related to different issues mentioned above.
(a) Yes - in mainstream financial reporting
(b) Yes - in CSR or sustainability report
(c) Implied - but not stated directly
(d) No
• Keyword(s):
'obesity', 'health issues', 'aging population', 'health', 'demographic',
'urbanization', 'urban', 'health'. ‘ESG issues’
- Scoring:
o ‘Yes – in mainstream financial reporting’ - the issue is clearly
identified as a risk, typically in ‘risks’ section of Annual Report.
o ‘Yes – in CSR or sustainability report’ - the issue is clearly
identified as a risk in the CSR or sustainability report.
o ‘Implied - but not stated directly’ - the issue is discussed but
not explicitly stated as a business risk
Practices – Company has conducted or issued research on the

following emerging risks:
We are looking if the company is undertaking some research on specific issue/risk
listed below. Only include primary research, white papers, or presentations. Also, look
for dedicated research team or in-house specialist who publishes research. Check
company website or have a quick google search.
Assessment of business risks related to

▪ obesity and emerging health issues - The indicator is called “obesity and
emerging health”, but we are only looking at “obesity” or “overweight.
Emerging health issues should go to the health and demographic changes.
▪ aging population and demographic change - look for information about
▪ urbanization trend - look for some high-level socioeconomic development
▪ health impact of environmental changes - Examples: rising incident of
▪ health and demographic changes – This is the “other” category. Anything
health and demographic research that does not fall in the 4 categories
above will be taken into consideration in this datapoint including emerging
health issue. Please provide details in the below “detail” section.
▪ Other Emerging Risk - detail– provide the issues identified or included in
health and demographic changes data point.
• Definition: Indicates if the company has conducted or issued research
related to different issues mentioned above.
(a) Yes - produces primary research
(b) Implied - through participation in an industry consortium
(c) No
• Keyword(s):
'urbanization', 'urban', 'health'.
- If company has products related to these risks, we CANNOT give
partial credits (implied). We are looking for explicit research here
- Scoring:
o Yes - produces primary research
• original research conducted in-house
•
Published white papers, primary research,
presentations.
o Implied - through participation in an industry consortium -
partnership with university, NGO, government, industry body
etc. to conduct climate change research.
Performance
Comment on the company's use of innovation approach to develop
products and services that mitigate exposure to emerging health and
demographic risks
• Definition: Describes company's use of innovation approach to develop
products and services that mitigate exposure to emerging health and
demographic risks.
N/A - Short Text
• Keyword(s):
- We are looking for innovative products that mitigate of health and
demographic changes.
- List the products used for assigning the score in the previous question
Products and services developed to address the following emerging risks

We are looking has products and services developed covering the specific issue/risk
listed below.
▪ obesity and emerging health issues - The indicator is called “obesity and
emerging health”, but we are only looking at “obesity” or “overweight”.
Emerging health issues should go to the health and demographic changes.
▪ aging population and demographic change - look for information about
▪ urbanization trend - look for some high-level socioeconomic development
▪ health impact of environmental changes - Examples: rising incident of
▪ health and demographic changes – This is the “other” category. Anything
health and demographic products that does not fall in the 4 categories
above will be taken into consideration in this datapoint including emerging

health issue
▪ Other Emerging Risks Details– provide the issues identified or included in
health and demographic changes data point
• Definition: Indicates if the company developed products and services to

address different issues mentioned above.
(a) Long-term benefits to customer/core business line
(b) Short-term benefits to customer/core business line
(c) Long-term benefits to customer/minor business line
(d) Short-term benefits to customer/minor business line
(e) No evidence
• Keyword(s):
'urbanization', 'urban', 'health'.
- Scoring can refer to either products or incentives built into standard
products, which serve to mitigate exposure of either the customer or
the company to emerging risks
- Long-term vs Short-term:
o Long-term – any product/services for more than one year.
Typically, L&H company has long-term products as they
provide term life insurance, annuity, or retirement plan
o Short-term – any product/services for less than one year.
- Core vs Minor business line:
o Core business line – major revenue contributor. No
quantitative threshold. Use own judgement here.
o Minor business line – small share of revenue.
- Most L&H insurance companies will have at least some exposure to
‘ageing populations’ product development – for many, this is a core
product.
Line of Business Risk Factors

Life and Health Lines as % of Total Premiums
• Definition: Indicates the percentage of the premium related to Life and
Health Lines.
• Keyword(s):
'life and health', 'L&H' ‘premium’
- Check the breakdown of premiums instead of the revenue breakdown.
- Use the gross written premium figure for the calculation for the P&C
and L&H premium.
- Enter zero if there’s no L&H Insurance.
Industry Guideline
- Multi-line Insurance - Make sure P&C and L&H premium should add up
to 100%.
Reinsurance Lines as % of Total Premiums

• Definition: Indicates the percentage of reinsurance that company has
assumed from other company for L&H insurance.
• Keyword(s):
'life and health', 'L&H', ‘reinsurance’, ‘assumed’
- Reinsurance value that companies have assumed from other company
for L&H insurance
- Assumed vs Ceded
o Assumed: provided service by the insurer consenting to
take risk from another insurer. Additional risk that the
company is taking.
o Ceded: insurer is transferring the risk of their portfolio to
another company. Reinsurance that the company is paying
to the reinsurance company.
- Use the total written premium figure as denominator for the
reinsurance line calculation
- Enter zero if there’s no reinsurance.
- Example: METLIFE, INC. 10K 2019
CCV Key Issue IHDR Key Issue

Property and Casualty Lines as (3,740+19)/(42,513+
% of Total Premiums 2020)=8.44%
Life and Health Lines as % of (23,938+14,835+1794+207)/(42,513+20

Total Premiums 2)= 91.56%
Reinsurance Lines as % of
19/(42,513+ 2020)= 0.04% (1,794+207)/(42,513+2020)=4.49%
Total Premiums
Labor Management
This issue evaluates the extent to which companies may face workflow disruptions
due to labor unrest or reduced productivity due to poor job satisfaction. Scores are
based on exposure to regions facing labor unrest, size of workforce, and corporate
restructuring/layoffs; workforce policies, benefits, training, and employee
engagement; and labor-related controversies
Performance
External recognition as employer of choice (last three years)
• Definition: This data point refers to the external recognition as employer of
choice for the last three years.
(a) Yes, more than one award in the last year
(b) Yes, one award in the last year
(c) Yes, more than one award in the last 3 years
(c) Not Disclosed
(e) No Value
• Keyword(s):
Award, best employer, best places to work, best company, best companies,
top employer, top 50
- The credit should be given if the company fulfills the following criteria
for any of the last three years (counting backwards from the month when
the company is being assessed):
o Only give credit for independent, 3rd party assessments,
should not be company initiated (e.g., great place to work
certification).
• Credible external lists and rankings include
▪ Fortune’s 100 Best Companies to Work
▪ Forbes
o Only consider international awards - Forbes, Fortune and
GPTW - given at a country/ global level. No local
recognitions to be considered even from the international
awards.
•Examples:
▪ Forbes - #45 Best place to work in
Technology – Yes
▪ GPTW - #12 Best place to work in India- Yes
▪ Fortune - #3 Best place to work in Bay Area-
No
o Only consider awards from Forbes, Fortune and Great Place
to Work given for workplace as a whole and not for sub-
segment like for mothers, LGBTQ+, etc.
o Exclude government awards (linked to facilitation in some
markets like China) and Indexes.
- Scoring:
o Yes, more than one award in the last year – if the company
had more than one award in the last year
• Examples:
▪ Forbes - 2021
▪ Fortune 100 - 2020
▪ Forbes - 2020
o Yes, one award in the last year – if the company had one
award in the last year
• Examples:
▪ Forbes - 2021
▪ Forbes - 2020
o Yes, more than one award in the last 3 years – if the
company had one award in the last 3 years
• Examples:
▪ GPTW - 2021
▪ Forbes – 2021
▪ GPTW - 2020
▪ Fortune 100 – 2020
▪ Forbes – 2019
▪ GPTW - 2019
o Not Disclosed – no disclosure
Company witnessed strikes / lock-outs in the last three years

• Definition: This data point provides information if the company witnessed
strikes / lockouts in the last three years.
(a) No
(b) Strike(s) affecting less than 1% of workforce
(c) Strike(s) affecting 1-10% of workforce
(d) Strike(s) affecting over 10% of workforce

(e) Strike(s) occurred but scope unknown
• Keyword(s):
Strike, lock-out, lock out, lockout, work stoppage
- This is aligned with Common LM/HCD: Strikes, work stoppages and
lockouts.
- Has company witnessed strikes/lockouts in the past 3 years?
o If yes, evaluate the impact.
- Scoring:
o No – no strikes/lock outs occurred
o Strike(s) affecting less than 1% of workforce – if
strikes/lock outs affected less than 1% of the workforce
o Strike(s) affecting 1-10% of workforce – if strikes/lock outs
affected less than 1-10% of the workforce
o Strike(s) affecting over 10% of workforce – if strikes/lock
outs affected more than 10% of the workforce
o Strike(s) occurred but scope unknown – strikes/lock outs
were mentioned to have occurred but no further details on
the employees affected
Exposure - Additional Exposure Indicators

Collective bargaining negotiation expected in next 12 months
• Definition: This data point provides information on the collective
bargaining negotiation expected by the company in next 12 months.
(a) Yes
(b) No
(c) No Evidence
• Keyword(s):
Collective bargaining, trade union, union, bargaining agreement
- Check details of company's disclosure on collective bargaining
negotiation expected in next 12 months
- Scoring:
o Yes – use this score if the company has collective
bargaining for employees within 12 months from the end
date of the fiscal year being assessed.
o No – use this score if the company explicitly stated that they

do not have collective bargaining for employees or outside
12 months of the end date of fiscal year being assessed.
o No Evidence – if the date of next collective bargaining is
blank or no evidence/no mention of collective bargaining for
employees
Collective Bargaining Negotiation

Child Datapoints Scoring Guidance
Year Enter the fiscal year assessed
Name of employee or workers’ Enter name of employee union or workers’ union, if
union available
Date of next collective Enter other details of collective bargaining
bargaining negotiation negotiation if exact date/month/year is not disclosed
Source: Date of next collective Enter reference document for collective bargaining
bargaining negotiation negotiation date.
• General Procedure
- Create additional rows if the company has multiple labor unions
disclosed
- Some companies may disclose collective bargaining agreements in
multiple countries or regions; this can be used as proxy for name of
employee union
Major Layoffs
• Definition: This data point refers to major layoffs of the company.
(a) Yes
(b) No
(c) Not Disclosed
• Keyword(s):
Restructuring, headcount reduction, workforce reduction, lay-off, lay off, job
cut, job cuts
- This is aligned with Common LM/HCD: Layoffs and M&A Events.
However, if there is M&A but doesn’t have any relation on Layoffs. Then
we scored this as No.
- Use your judgment on whether the transaction was big enough to have
a substantial effect on meshing of cultures, employee morale, etc.
- Scoring:
o Yes – This is an exposure indicator; this data point indicates
whether the company announced a major layoff in the last
three years.
• Major layoffs are categorized as decreasing staff by
10% or more. If there is a change in the number of
employees indicating significant reduction in the
numbers (1,000 people or 10% of the previous year’s
workforce), this may be attributable to layoffs
o No – No significant reduction/no major layoffs
o Not Disclosed – do not use this scoring
Practices - Strategy
Investment in automation/robotics
• Definition: This data point refers to the investment in automation/ robotics
of the company.
(a) Incurred
(b) Planned
• Keyword(s):
Automation, automate, robotics, AI
- Provide information if the company invested or planning to invest in
automation/ robotics
- Scoring:
o Incurred – if the company mentions its investment in
automation/robotics, whether for R&D or for actual projects,
in the past tense (meaning that it has invested X amount in
the fiscal year or from previous years)
o Planned – if the company mentions a target investment in
automation/robotics and no further investment have been
spent
Expected gains on productivity/ operational costs

• Definition: This data point refers to the expected gains on productivity/
operational costs from automation/ robotics
N/A = free text
• Keyword(s):
Automation, automate, robotics, AI

- Provide information on the expected gains on productivity/ operational
costs from automation/ robotics
Evidence of Anti-Discrimination/ Diversity and Inclusion policy

• Definition: This data point refers to any proof which indicate that the
company has an anti-discrimination or diversity and inclusion policy.
(a) Yes
(b) No
(c) Not Disclosed
• Keyword(s):
Discrimination, diversity, gender, inclusion
- Ensure that the company’s stated policy on anti-
discrimination/diversity and inclusion is pertaining to its own
operations
- Search for ILO conventions or company's stated policy on anti-
discrimination/diversity and inclusion applicable to its own operations
- Scoring:
o Yes – Evidence of Anti-Discrimination/ Diversity and
Inclusion policy is found. We could also consider if the
company is Participant in UNGC Signatory but no disclosure
on any policy this can be scored.
o No – Explicit disclosure that the company does not have any
anti-Discrimination/ Diversity and Inclusion policy
o Not Disclosed – No evidence found. This should also be
selected if the company's Anti-Discrimination/ Diversity and
Inclusion policy only applies to its suppliers.
Evidence of child labor provision in the internal policy

company has a child labor provision in the internal policy.
(a) Yes
(b) No
(c) Not Disclosed
• Keyword(s):
Child labor
- Ensure that the company’s stated policy on child labor is pertaining to
its own operations
- Search for ILO conventions or company's stated policy on child labor
applicable to its own operations
- Do not follow the validation rule ‘Scoring for datapoint should be 'Yes'
for UK domicile’. Mark this data point as ‘Yes’ only if there is
evidence/disclosure that the child labor provision is in the internal
policy of the company. **Retained score for published issuer.
- Scoring:
o Yes – Evidence of child labor policy is found. We could also
consider if the company is Participant in UNGC Signatory
but no disclosure on any policy this can be scored.
child labor policy
selected if the company's forced labor policy only applies to
its suppliers.
Evidence of forced labor provision in the internal policy

company has a forced labor provision in the internal policy.
(a) Yes
(b) No
(c) Not Disclosed
• Keyword(s):
Forced labor
- Ensure that the company’s stated policy on forced labor is pertaining
to its own operations
- Search for ILO conventions or company's stated policy on forced labor
applicable to its own operations.
- Do not follow the validation rule ‘Scoring for datapoint should be 'Yes'
for UK domicile’. Mark this data point as ‘Yes’ only if there is
evidence/disclosure that the forced labor provision is in the internal
policy of the company. **Retained score for published issuer.
- Scoring:
o Yes – Evidence of forced labor policy is found. We could

also consider if the company is Participant in UNGC
Signatory but no disclosure on any policy this can be scored.
forced labor policy
selected if the company's forced labor policy only applies to
its suppliers.
Evidence of freedom of association provision in the internal policy

company has a freedom of association provision in the internal policy
(a) Yes
(b) No
(c) Not Disclosed
• Keyword(s):
Freedom of association
- Ensure that the company’s stated policy on freedom of association is
pertaining to its own operations
- Search for ILO conventions or company's stated policy on freedom of
association applicable to its own operations
- Scoring:
o Yes – Evidence of freedom of association policy is found.
We could also consider if the company is Participant in
UNGC Signatory but no disclosure on any policy this can be
scored.
freedom of association policy
selected if the company's freedom of association policy
only applies to its suppliers.
Policies to address labor rights in core operations

• Definition: This data point refers to the policies to address labor rights in
core operations (if the company’s labor rights policy is following a certain
regulation/convention/standard)
(a) Policy covers ILO core conventions plus additional protections
(b) Evidence of commitment to abide by the ILO's core conventions, UN

Global Compact or equivalent
(c) Policy is general or does not cover all ILO core conventions
(e) No evidence
• Keyword(s):
Labor rights, ILO, International Labour Organization, UNGC, UN Global
Compact, United Nations Global Compact, human right, labour rights
- It is a valid disclosure if the company had a section in their
AR/CSR/Code of Conduct on their commitment to labor rights, however
it is also valid to use a company's human rights policy if it has stated
child/forced labor, anti-discrimination, freedom of association (even if
it was only mentioned in a sentence/paragraph)
- Scoring:
o Policy covers ILO core conventions plus additional
protections – Select this option if the company's labor
policy covers and is aligned with ILO core conventions and
other additional protections.
o Evidence of commitment to abide by the ILO's core
conventions, UN Global Compact or equivalent – Select this
option if the company has commitments to align and follow
its labor policy with ILO's core conventions, UN Global
Compact or equivalent
o Policy is general or does not cover all ILO core conventions
– General statements about the company's labor rights
policy. In addition, we could score this if Evidence of Child
Labor and Forced Labor provision in the internal policy
answered as Yes.
norms – Currently not used; please refrain from using
Percentage of workforce covered by trade unions/ collective agreements

• Definition: This data point records the percentage of workforce covered by
trade unions/ collective agreements
N/A = free text
• Keyword(s):
- Enter the percentage of total workforce covered by collective
agreements (either calculated or disclosed)
- Enter ‘zero’ if the company explicitly disclosed that they do not have
workforce covered by trade unions/ collective agreements.
- The collective bargaining agreements/trade unions should cover all
employees (permanent, full-time, temporary, and part-time
employees).
- We could use Full time employees as long as can be calculated
- If calculation is needed:
o (Employees covered by trade unions or collective
bargaining/Total employees) * 100
Estimate Key: Percentage of workforce covered by trade unions/ collective

agreements
• Definition: This data point describes the data entered in Percentage of
workforce covered by trade unions/ collective agreements
(a) Reported
(b) Estimated
• Keyword(s):
- Answer whether the workforce covered by collective agreements is
estimated or disclosed.
- Scoring:
o Reported – Select this option if the value was explicitly
disclosed by the company
o Estimated – Select this option if the value was estimated or
derived from a computation. Note: if the value was
calculated using full time or the disclosure is for full time
employees only. We scored this.
Variable performance-based component to pay

• Definition: This data point refers to whether the company has
incentives/bonuses for non-officer employees when they have performed
well/achieved performance-based targets provided by the company
(a) Strong performance-based incentive pay structure covers all
employees
(b) Selective performance-based incentive pay for non-officer staff

(c) No evidence of variable incentive pay for non-officer staff
• Keyword(s):
Performance bonus, performance incentive, bonus incentive, variable
incentive
- This includes incentive pay, bonuses, and cash, and cash profit sharing.
Do not include profit sharing that goes directly into a retirement plan.
- This must be for non-officer employees. Do not consider if the
performance-based pay is for executives, board members,
management, officers.
- Scoring:
o Strong performance-based incentive pay structure covers
all employees – company’s performance-based incentive is
for all employees
o Selective performance-based incentive pay for non-officer
staff – company’s performance-based incentive is
mentioned/evident but does not cover all non-officer
employees or has an unknown scope
o No evidence of variable incentive pay for non-officer staff
– no disclosure
Practices – Performance & Initiatives

Support for degree programs or certifications
• Definition: This data point provides information if there is a support for
degree programs or certifications in the company (company supports
employees in achieving higher academic studies/degrees or certifications)
(a) Program covers all employees (including part-time and contractors)
(b) Program covers all permanent full-time employees (excluding part-time
and contractors)
(c) Program exists but does not cover all employees
(d) Program exists but no indication of scope
(e) No evidence
• Keyword(s):
Tuition, university, certification, degree, higher education
- Score if the company provides support for degree programs through
tuition reimbursement fees/sabbaticals, new certifications, etc.
- Scoring:
o Program covers all employees (including part-time and

contractors) – The company's full-time employees,
including part-time and contractors, are eligible to
participate in its degree programs or certifications
programs or initiatives
o Program covers all permanent full-time employees
(excluding part-time and contractors) – The company's
full-time employees are eligible to participate in its degree
programs or certifications programs or initiatives
o Program exists but does not cover all employees – The
company has degree programs or certifications programs
or initiatives but there is a disclosure which indicates that it
does not cover all employees
o Program exists but no indication of scope – General
statement on degree programs or certifications programs
or initiatives (vague disclosure)
o No evidence – No information found
Leadership training and skills development

• Definition: This data point provides information if there is a leadership
training and skills development provided by the company for their
employees
(a) Program covers all employees (including part-time and contractors)
(b) Program exists but does not cover all employees
(c) Program exists but no indication of scope
(d) No evidence
(e) Program covers all permanent full-time employees (excluding part-time
and contractors)
• Keyword(s):
Leadership, managerial, skills training
- Score if the company provides a leadership training or skills training
that would provide opportunity for the leaders to move up or into a new
role at the company (e.g., Training for managers, professional
leadership development programs)
- Scoring:
o Program covers all employees (including part-time and
contractors) – The company's full-time employees,
including part-time and contractors, are eligible to
participate in its leadership training and skills development

programs
o Program exists but does not cover all employees – The
company has leadership training and skills development
programs but there is a disclosure which indicates that it
does not cover all employees
o Program exists but no indication of scope – General
statement on leadership training and skills development
programs (vague disclosure)
o No evidence – No information found
o Program covers all permanent full-time employees
(excluding part-time and contractors) – The company's
full-time employees are eligible to participate in its
leadership training and skills development programs
Restructuring policies and programs

• Definition: This data point refers to the restructuring policies and programs
of the company.
(a) Evidence of severance pay and assistance with outplacement,
reemployment or retraining
(b) Evidence of assistance with outplacement, reemployment or retraining
(c) Evidence of severance pay
(d) No disclosure but strong collective bargaining indicates restructuring
programs are likely
(e) No evidence
(f) The company has not experienced any major layoffs
• Keyword(s):
Restructuring, headcount reduction, workforce reduction, lay-off, lay off,
severance pay, severance
- Evaluate company's restructuring policies and programs for their
employee not for Executive Management or Board of Directors
- Scoring:
o Evidence of severance pay and assistance with
outplacement, reemployment, or retraining – Score if there
is evidence of severance pay AND assistance with
outplacement, reemployment, or retraining
Evidence of assistance with outplacement, reemployment,

o
or retraining – Score if there is evidence of assistance with
outplacement, reemployment or retraining ONLY
o Evidence of severance pay – Score if there is evidence of
severance pay ONLY
o No disclosure but strong collective bargaining indicates
restructuring programs are likely – Score if company has
no disclosure on restructuring programs but are LIKELY to
have such programs based on strong collective bargaining
o No evidence – Avoid using no evidence.
o The company has not experienced any major layoffs –
company has not experienced major layoffs
Industry Specific
- Sub – Industry: Food Retails, Restaurants
o This should be aligned with Layoff
o Scoring:
• The company has not experienced any major
layoffs – scored if the company had no cases of
layoffs during past three years.
• No evidence – this could be scored if there is one
cases in layoff but have no restructuring for the last
three years.
Opportunities in Clean Tech

in the market for environmental technologies. Scores are based on exposure to
potential opportunities based on business model and policy incentives; innovation
capacity and strategic development initiatives; and revenue derived from clean
technologies.
Performance
**General scoring for the different businesses, products, and/or services involvement
on clean technology. For all the datapoints under this Key Issue, the clean
technologies that should be evaluated and considered are products or services sold
or provided to the clients or customers of the companies being assessed and NOT
FOR THEIR OWN OPERATIONS.
• Pure play (revenues >50%): company's revenues mostly come from the
products or services offered (company is the leading player in the given
market)
• Core Business (revenues 20-50%): Products or services in this area
constitute at least half of revenues (you may not be able to get exact
figures, but make your best estimate) or the company is a major player in
the market
• Non-core business (revenues <20%): relatively minor component
manufacturing, products or services in this area constitute less than 20%
of revenues (make your best estimate), or the business segment is
marginal to the company
• R&D underway /exploring opportunities: a company is engaged in R&D in
this area and/or has one or more offerings but they represent a negligible
portion of revenues
• No involvement: do not choose as an option; if company is not involved on
the clean tech mentioned in the data point, choose No Value
Alternative Energy - Renewables

Involvement in generation or development of wind power capacity
• Definition: This data point refers to the products/services offered by the
company to the customers/consumers particularly on the involvement in
energy production from wind
a) No Value
b) Pure play (revenues >50%)
c) Core business (revenues 20-50%)
d) Non-core involvement (revenues <20%)

e) R&D underway / exploring opportunities
f) No involvement
• Keyword(s):
Wind, air, energy, wind energy
- Score based on involvement with energy production from wind.
Producers of energy from renewable resources like Wind, Solar,
Geothermal, Biomass, Biofuel, Waste-based, Tidal or Small Hydro.
Example: Manufacturers of chemicals/components used in
systems to generate this energy, for instance plastic manufacturers
who make carbon fibers for windmills, chemicals for solar
conductivity, agro companies selling residue for power generation
etc.
- This data point should not be scored based on the company's own
initiatives to improve their own facilities/operations and is
specifically for the products/services they offer to their
consumers/customers.
- There may be instances where a specific clean technology applies
to multiple datapoints; this is valid. Ensure that all the applicable
datapoints are scored accordingly using the clean technology
products/services offered by the company
- Revenue percentage shows on the 'Revenue derived from clean
tech activities' table. When selecting "pure play" and "core
business", make sure you have strong and explicit evidence. At the
same time, the presence of company's revenues (percentage) on
the said table means that there should be a disclosure on the
specific category from where the percentage is located since there
are revenues being generated from that segment.
Industry Guidelines
- Sector/Industry/Sub-Industry: Semiconductors, Electronic
Equipment, Instruments & Components Industry
o If company’s components are used in turbines, credit is
still given (even if the company has indirect involvement
with the turbines)
- Sector/Industry/Sub-Industry: Trading Companies & Distributors
o Companies under these industry don’t directly involve
themselves in clean tech
o Highest score that can be given is Non-core involvement
(revenues <20%);
o For the score of R&D underway / exploring opportunities,

the company must have a disclosure that mentions plans
of investing in Clean Tech opportunities for trading and
distribution (this is because usually, there is no disclosure
on R&D)
Involvement in generation or development of solar power capacity

solar energy production
a) No Value
f) No involvement
• Keyword(s):
Solar, solar energy, energy, sun, photovoltaic, [Industry-specific keywords:
solar modules, solar cells, photovoltaic, solar ingot]
- Score based on involvement with solar energy production.
etc.

Industry Guidelines
- Sector/Industry/Sub-Industry: Semiconductors, Electronic
Equipment, Instruments & Components Industry
o Specific examples are solar modules, solar cells,
photovoltaic, solar ingot
• If the company is involved in these, we may mark
Pure play (revenues >50%)
Involvement in generation or development of geothermal power capacity

geothermal energy production
a) No Value
f) No involvement
• Keyword(s):
Geothermal, geo, thermal, energy
- Score based on involvement with geothermal energy production.
etc.

Involvement in generation or development of waste-based power

capacity
energy production from wastes
a) No Value
f) No involvement
• Keyword(s):
Waste, energy, waste-energy, residue, plastic. waste-based, incineration,
sludge
- Score based on involvement with energy production from wastes.
etc.

Involvement in generation or development of wave tidal power capacity

energy production from tidal waves
a) No Value
f) No involvement
• Keyword(s):
Wave, tide, tidal, tidal energy, energy, wave energy
- Score based on involvement with energy production from tidal
waves. Producers of energy from renewable resources like Wind,
Solar, Geothermal, Biomass, Biofuel, Waste-based, Tidal or Small
Hydro. Example: Manufacturers of chemicals/components used in
etc.

Involvement in generation or development of small hydro power capacity

hydropower energy production
a) No Value
f) No involvement
• Keyword(s):
Hydro, water, energy, hydropower, hydro power, hydro-power, hydroelectric
- Score based on involvement with hydropower energy production.
etc.

Involvement in development or distributing biomass

biomass energy production
a) No Value
f) No involvement
• Keyword(s):
Biomass, bio-mass, energy
- Score based on involvement with biomass production. Producers
of energy from renewable resources like Wind, Solar, Geothermal,
Biomass, Biofuel, Waste-based, Tidal or Small Hydro. Example:
Manufacturers of chemicals/components used in systems to
generate this energy, for instance plastic manufacturers who make
carbon fibers for windmills, chemicals for solar conductivity, agro
companies selling residue for power generation etc.
Alternative Energy – Alternative Fuels

Involvement in developing or distributing biodiesel
biodiesel as an alternative fuel production
a) No Value
f) No involvement
• Keyword(s):
Biodiesel, alternative fuel, fuel, biofuel, bio fuel, bio-fuel, bio-diesel
- Score based on involvement in biodiesel as an alternative fuel
production. Example: Fertilizer/agricultural chemical companies
producing biofuels/biodiesel from agro residues
Involvement in developing or distributing biogas

in biogas as an alternative fuel production
a) No Value
f) No involvement
• Keyword(s):
Biogas, alternative fuel, fuel
- Score based on involvement in biogas as an alternative fuel
production. Example: Fertilizer/agricultural chemical companies
producing biofuels/biodiesel from agro residues
Involvement in developing or distributing cellulosic ethanol (excluding

corn)
cellulosic ethanol (excluding corn) as an alternative fuel production
a) No Value
f) No involvement
• Keyword(s):
Cellulosic ethanol, cellulose, ethanol, alternative fuel, fuel, oil, rice, bran
- Score based on involvement in cellulosic ethanol (excluding corn)
as an alternative fuel production. Example: Agriculture-based
companies involved in production of ethanol (cellulosic except for
corn)
Involvement in developing or distributing fuel cells/hydrogen systems

fuel cells/hydrogen systems production or distribution for alternative fuel
production
a) No Value
f) No involvement
• Keyword(s):
Fuel cell, hydrogen system, hydrogen cell
- Score based on involvement in fuel cell/hydrogen system
production/distribution (alternative fuel).
Energy Efficiency – Power Management

Involvement in demand-side power management
demand-side power management
a) No Value
f) No involvement
• Keyword(s):
Energy management system, DSM, demand-side management, demand
side management, metering equipment (NOTE: must be for energy use)
- Score based on involvement in demand-side power management.
Example: Home Energy Management System (HEMS), Building
Energy Management System (BEMS), Factory Energy Management
System (FEMS), Community Energy Management System (CEMS)
o Look for products that allow the company's customers to
monitor their energy use

Industry Guidelines
- Sector/Industry/Sub-Industry: Information Technology sector
o Look for software/s that enables clients to monitor or
manage energy use (usually targeted for Utilities clients)
Involvement in developing smart grid

managing power dependence from consumers perspective by smart
metering, development of smart grids etc.
a) No Value
f) No involvement
• Keyword(s):
Smart meter, smart grid, energy efficiency, energy, power, green grid
- Score based on involvement in managing power dependence from
consumers perspective by smart metering, development of smart
grids etc.

Industry Guidelines
o Look for any software that assists or is being used for smart
grid solutions
Involvement in production or distribution of batteries

production of Lithium-ion batteries or production of lithium mineral
a) No Value
f) No involvement
• Keyword(s):
Battery, lithium. Li-on
- Score based on involvement in production of Lithium-ion batteries
or production of lithium mineral
-
There may be instances where a specific clean technology applies
Industry Guidelines
- Sector/Industry/Sub-Industry: Auto components
o Only consider batteries that are tailor made for
electric/hybrid vehicles. Batteries for conventional vehicles
should not be considered as a clean tech product.
o Look for components or raw materials that are used in
battery/for the development of batteries
Involvement in production or distribution of energy storage technology Commented [SAM71]: [Pending for Content] Need
• Definition: This data point refers to the products/services offered by the more clarity on the definition
company to the customers/consumers particularly on the involvement in Commented [SAM72R71]: Does this only cover
the storage of power/energy (solar, wind, bio) renewables ?
a) No Value
f) No involvement
• Keyword(s):
Energy, storage, store, power, energy storage
- Score based on involvement in the storage of power/energy (solar,
wind, bio). Energy storage is different from memory storage
(though it does help in energy saving)

Involvement in production or distribution of nano-technology

nanotechnology for power management or energy efficiency
a) No Value
f) No involvement
• Keyword(s):
Nano tech, nanotech, power, efficiency, nano particles
- Score based on involvement in manufacturing and/or distributing
nanotechnology for power management or energy efficiency
Industry Guidelines
- Sector/Industry/Sub-Industry: Chemicals Industry (sub-industries -
Diversified Chemicals, Commodity Chemicals, Specialty Chemicals,
Industrial Gases, Fertilizers & Agricultural Chemicals)
o Ensure that nano particles are being used for energy
efficiency applications
Involvement in developing energy solutions for household products

producing/developing energy solutions (energy efficiency/power
management) for household products
a) No Value
f) No involvement
• Keyword(s):
Household product, energy efficiency, energy efficient, save
- Score based on involvement in producing/developing energy
solutions (energy efficiency/power management) for household
products. Example: Electronic/Electrical/Semiconductor
companies involved in reducing energy consumption of household
products like TV, Refrigerators, Mobile Phones, Computers, Tablets
etc.

Involvement in production or distribution of superconductors

the production of superconductors or distribution of superconductors
a) No Value
f) No involvement
• Keyword(s):
Superconductor, resistance
- Score based on involvement in the production of superconductors
or distribution of superconductors

Involvement in natural gas power generation

natural gas power generation
a) No Value
f) No involvement
• Keyword(s):
Natural gas, energy, fuel
- Score based on involvement in natural gas power generation.
Example: Companies that generate power from natural gas
Energy Efficiency – Fuel Economy

Involvement in developing or distributing advanced materials
producing advanced chemicals contributing to reduction in fuel

requirement/energy dependence
a) No Value
f) No involvement
• Keyword(s):
Light-weight, lightweight, carbon fiber, advanced engineering material,
advanced material, aluminum, carbon fibre, high value-added material,
magnesium, memory alloy, memory polymer, nanocomposite, steel,
synthetic, thermoplastic, titanium
- Score based on involvement in producing advanced chemicals
contributing to reduction in fuel requirement/energy dependence
o Developing better materials from the traditional materials
(e.g making them thinner, smaller, conductive, efficient,
etc.)
Industry Guidelines
- Sector/Industry/Sub-Industry: Auto components
o Example: tires with reduced rolling resistance
- Sector/Industry/Sub-Industry: Building Products
o Check if the company has components/products/services

that offer the development of better materials from the
traditional materials (mostly for vehicles)
Involvement in developing or distributing hybrid or electric vehicles

developing electric/hybrid vehicles and/or producing lighter materials for
facilitating production of EVs/HVs
a) No Value
f) No involvement
• Keyword(s):
Hybrid vehicle, HV, Electric vehicle, EV, hybrid, energy, power, PHEV, plug-
in hybrid electric vehicle, hybrid car
- Score based on the involvement in producing or distributing hybrid
vehicles (HV) or electric vehicles (EV)
Industry Guidelines
- Sector/Industry/Sub-Industry: Hardwater Components
oIf the product/service is a

part/component/material/equipment used for Electric
Vehicles (usually, these companies have indirect
involvement), credit Non-core involvement (revenues
<20%)
- Sector/Industry/Sub-Industry: Trading & Distributors
o Since companies under this industry do not
manufacture/create/provide materials or parts for hybrid or
electric vehicles, vehicle rentals are valid for the credit of
Non-core involvement (revenues <20%) (due to indirect
involvement with hybrid of electric vehicles)
Energy Efficiency – Industrial Operations & Automation

Involvement in production or distribution of industrial automation
technologies
helping buyers automate their industrial processes
a) No Value
f) No involvement
• Keyword(s):
Robotic, automation, automate, IOT, Industrial Automation, Internet of
Things, smart, smart system, smart control, smart HVAC, Building
Automation Systems, BAS
- Score based on involvement in helping buyers automate their
industrial processes (increased mechanization, robotics, AI etc.)
- We can differentiate industrial automation products/services
depending on the customer base. These technologies will be more
focused on digital transformation of companies (B2B – business to
business), so the keyword here is "industrial."
o Examples could be robotics technology in the
manufacturing assembly, industrial automation
products/services could entail replacement of humans or
conventional machineries to make work faster, smart
systems, smart water controls, smart HVAC systems,

Building Automation Systems (BAS).
Industry Guidelines
- Sector/Industry/Sub-Industry: Semiconductors Equipment sub-
industry
o If evidence is found for this datapoint, it should at least have
the scoring of Non-core involvement (revenues <20%)
because they support semiconductors manufacturing
- Sector/Industry/Sub-Industry: Technology Hardware, Storage &
Peripherals
o Examples are: heavy equipment type (e.g. computers),
electronic components, or instruments that support the
manufacturing of robots
Involvement in developing or distributing optimization technologies &

systems
developing optimization technologies
a) No Value
f) No involvement
• Keyword(s):
Optimize, optimization, technology, optimization technologies,
optimization technology, cloud, digitize, IOT, Internet of Things, AI, Artificial
Intelligence, Industrial Automation, BPM, Business Process Management,
RPA, Building Information Modelling, 5G technologies – TMT, cloud
computing, data center optimization, data virtualization, sustainability IT
consulting services, Infrastructure-as-a-Service (IAAS), Platform-as-a-
Service (PAAS)
- Score based on involvement in developing optimization
technologies
- Optimization technologies are more applicable to B2C (business to
customer), like online payment transactions thru mobile apps. But
can also have B2B (business to business) products but more on
providing systems improvement like shifting of in-office work to
remote work set-up. Unlike industrial automation, optimization
technologies and systems do not replace humans in performing
certain tasks, but these are tools that may help "optimize" the work
and therefore perform better at a more efficient use of resources
(both time and money).
o Examples are companies who have smart monitoring
products which are linked to a user app (e.g., for individuals)
or a computerized building system (e.g., for commercial
clients) and that allow customers to monitor energy/water
usage/leaks more efficiently. Some companies will also
have software-related offerings such as Building
Information Modelling software, which optimize and
streamline construction-related processes

Industry Guidelines
- Sector/Industry/Sub-Industry: Application Software, System
Software, IT Consulting and other services
o Default should be Core business (revenues 20-50%)
- Sector/Industry/Sub-Industry: Internet Services & Infrastructure
o Default should be Pure play (revenues >50%) for Data
Centers and Cloud companies
- Sector/Industry/Sub-Industry: Semiconductor equipment
o Examples are
• Manufactures of EUV (extreme ultraviolet) like
lithography equipment
• Infrastructure-as-a-Service (IAAS), Platform-as-a-
Service (PAAS)
Pollution Prevention & Control - Soil

Involvement in waste treatment operations or development and
distribution of waste treatment technologies
waste treatment and developing technologies for waste treatment
a) No Value
f) No involvement
• Keyword(s):
Waste, treatment, waste treatment, pollution, toxic, sludge
- Score based on involvement in waste treatment and developing
technologies for waste treatment (companies re-using/recycling
their own waste to use it internally do not qualify)
o Common in Industrial Machinery industries that is involved
in treating sludges/wastes
o Common in Construction & Engineering industries involved
in building the structures for waste treatment plants
-
This data point should not be scored based on the company's own
Industry Guidelines
- Sector/Industry/Sub-Industry: Industrial Machinery
o Example: equipment that is needed to build waste treatment
plants (companies involved in treating sludge/wastes)
- Sector/Industry/Sub-Industry: Construction & Engineering
o Example: involvement in building in waste treatment
plants/structures
Involvement in development and distribution of environmental

remediation technologies
soil remediation.
a) No Value
f) No involvement
• Keyword(s):
Remediation, soil, heavy metal, pollution, pollutant, toxic, environmental
remediation, soil remediation
-
Remediation is the process of removing pollutants (like heavy
metals) from an area (soil).
- Score based on involvement in soil remediation. Example: Ag-chem
companies involved in bio-based fertilizers/soil additives that help
remediate the soil
Industry Guidelines
- Sector/Industry/Sub-Industry: Construction & Engineering
o There are instances where remediation is provided by the
company as services for their clients/customers
Pollution Prevention – Reuse & Recycling

Involvement in development and distribution of reused products or
products using recycled waste
products, technology or services that enable recycling, remanufacturing, or
re-use of raw materials, products, or waste on a more general or wider
industry scope.
a) No Value
f) No involvement
• Keyword(s):
Recycle, recycling, recycled, waste, reuse
- Score based on involvement in products, technology or services
that enable recycling, remanufacturing, or re-use of raw materials,
products, or waste on a more general or wider industry scope
o This should not be confused with the datapoint for "Green
Building - Materials Involvement in development and
distribution of products using recycled materials" which
focuses on products related to recycling of building or
construction materials
- Those meant for construction-related applications are not valid in
this data point and should be scored under “Involvement in
development and distribution of products using recycled materials”
Industry Guidelines
- Sector/Industry/Sub-Industry: Semiconductors
o Example: reclaimed wafers (old wafers that companies use
for testing/for repurposing)
o Example: companies that offer rentals of equipment like
refurbished machinery that they still include in their leasing
lines
Pollution Prevention & Control – Air Quality

Involvement in developing or distributing environmental information
technology
making instruments/systems or technologies that enable the
measurement of air emissions or air quality.
a) No Value
f) No involvement
• Keyword(s):
Environmental, technology, environmental information, SOx sensor, NOx
sensor, CO2 sensor, emission survey, emission measurement, green
information technology, green IT, environmental IT, gas detection sensor
- Score based on involvement in making instruments/systems or
technologies to gather environmental information on air quality.
Examples include but are not limited to: SOx, NOx, CO2 sensors,
methane emission surveying technology, etc.
Industry Guidelines
- Sector/Industry/Sub-Industry: Electronic Components and

Instruments
o Examples include detection sensor/devices used for
determining gas levels
o Check if the company’s products branch out in the pollution
control aspect as these do not have a core involvement
(usually scored as Non-core involvement (revenues <20%)
Involvement in developing or distributing conventional pollution controls

company to the customers/consumers particularly on the involvement
products, technology or services that enable the reduction of air pollution
or air emissions.
a) No Value
f) No involvement
• Keyword(s):
Pollution, pollutant, toxic, dust collector, electro-static precipitator, gas
exhaust filter
- Score based on involvement in making
chemicals/products/equipment to reduce pollutants. Examples
include but are not limited to dust collectors, electro-static
precipitators, gas exhaust filters, etc.

Involvement in carbon capture & storage activities

manufacturing products/technologies that help with carbon capture and
storage.
a) No Value
f) No involvement
• Keyword(s):
Carbon capture, carbon storage, carbon, carbon sequestration, CCS
- Carbon capture and storage is the process of taking carbon from
the atmosphere and storing it to reduce carbon in the air.
- Score based on involvement in manufacturing
products/technologies that help with carbon capture and storage.
Sustainable Water – Water Infrastructure & Distribution

Involvement in water infrastructure and distribution
water distribution activities
a) No Value
f) No involvement
• Keyword(s):
Water distribution, water, pipe
- Score based on involvement in water distribution activities
(example: water utilities)
Sustainable Water – Water Resource Management & Efficiency

Involvement in rainwater harvesting or development of rainwater
harvesting systems
providing systems/solutions for rainwater harvesting
a) No Value
f) No involvement
• Keyword(s):
Rainwater, rain water, harvesting, harvest
- Score based on involvement in providing systems/solutions for
rainwater harvesting
Involvement in production or distribution of smart metering devices

manufacturing smart water meters and/or providing smart metering
services
a) No Value
f) No involvement
• Keyword(s):
Smart meter
- Score based on involvement in manufacturing smart water meters
and/or providing smart metering services.
Involvement in developing or distributing drought-resistant seeds

developing drought-resistant seeds
a) No Value
f) No involvement
• Keyword(s):
Seed, drought-resistant, drought resistant
- Score based on involvement in developing drought-resistant seeds.
Most likely found in agricultural-chem companies

Sustainable Water – Water Treatment & Purification

Involvement in desalinization operations or development and distribution
of desalinization technologies
desalinization technologies.
a) No Value
f) No involvement
• Keyword(s):
Desalinization, desalinate, pollutant, pollution, mineral, salt
- Desalination is the process of removing salt/minerals from water.
- Score based on involvement in desalinization technologies.

Involvement in waste water treatment operations or development and

distribution of waste water treatment technologies
providing wastewater treatment technology/solutions/chemicals
a) No Value
f) No involvement
• Keyword(s):
Waste water, wastewater, treatment, pollution, pollutant, toxic
- Score based on involvement in providing wastewater treatment
technology/solutions/chemicals.
Green Building - Applications

Involvement in developing or distributing LED lighting
providing LED solutions, electronic companies providing LED Displays
a) No Value
f) No involvement
• Keyword(s):
LED, OLED, display, light emitting diode
- Score based on involvement in providing LED solutions, electronic
companies providing LED Displays. OLEDs are given credit here.
Involvement in developing or distributing compact fluorescent lighting

Compact Fluorescent Lighting (CFL)
a) No Value

f) No involvement
• Keyword(s):
Compact Fluorescent Lighting, CFL, fluorescent
- Score based on involvement in Compact Fluorescent Lighting (CFL)
– obsolete
Green Building – Real Estate Investments, Engineering, Construction

Involvement in developing or managing green-certified properties
• Definition: This data point refers to the products/services offered by
the company to the customers/consumers particularly on the
involvement in developing properties that are LEED certified and
other green building certifications
a) No Value
f) No involvement
• Keyword(s):
See non-exhaustive list of accepted green building standards

Green Building Standard Origin
BEAM Hong Kong
BEE India
BELS* Japan
BOMA Canada
BREEAM United Kingdom
CALENER Spain
CASBEE Japan
China Three Star (All levels considered
China
“green certified”)
Development Bank of Japan Japan
DGNB Germany
EDGE International Finance Corporation
Energy Star* United States
Green Building Index Malaysia
Green Garage Certification United States
Green Globe United States
Green Globes Canada
Green Key Denmark
Green Mark Singapore
Green Standard Russia
Green Star Australia
Green Star SA South Africa
GRIHA India
HQE France
Homestar New Zealand
IGBC India
ISO 14001 Switzerland
ISO 21931 Switzerland
ISO 50001* Switzerland
Leadership in Energy and Environmental
United States
Design (LEED)
Living Building Challenge United States
Minergie* Switzerland
NABERS* must be equal or higher than 3.5
Australia
stars
National Green Building Standard United States
Denmark, Finland, Iceland,
Nordic Ecolabelling
Norway, Sweden
Qualiverde Brazil
Pearl Rating System for Estidama must be
United Arab Emirates
equal or higher than 2 pearls
Superior Energy Performance United States
The Sustainable SITES Initiative United States
Miljöbyggnad Sweden
Passive House (Passivhaus) Sweden, Germany

GreenBuilding* Sweden
KfW Efficiency House 40, 40 plus, and 55 Germany
*One-dimensional valid certifications, as
they focus on energy
- Score based on involvement in developing properties that are LEED
certified and other green building certifications mentioned in the
Keyword section above. Most likely found in Real Estate companies
and Construction companies
o If the certification is a well-known certification and maybe
equivalent of those international standards like LEED, it can
be considered (see table above on recognized
certifications)
Green Building - Materials

Involvement in development and distribution of products using recycled
materials
products, technology or services that enable the re-use of recycling
construction or building materials.
a) No Value

f) No involvement
• Keyword(s):
Recycled, recycle, waste, reuse, construction material, building material,
circular, circular economy
- Score based on involvement products, technology or services that
enable the re-use of recycling construction or building materials
o This is focused on re-use or recycling of construction
materials and should not be confused with the datapoint in
Pollution Prevention – Reuse & Recycling (Involvement in
development and distribution of reused products or
products using recycled waste), which would have wide
industry scope
- Construction-related applications are valid in this data point
Industry Guidelines
- Sector/Industry/Sub-Industry: Building Products, Construction &
Engineering, and Manufacturing Industries
o Example: company focused on circular economy
(recycling/reusing materials)
Involvement in production or distribution of blended cement

producing/distributing blended cement. Blended cement is a type of

cement which includes alternative raw materials other than limestone.
a) No Value
f) No involvement
• Keyword(s):
Blended cement, cement, fly ash
- Score based on involvement in producing/distributing blended
cement. Example: Most likely found in Construction companies and
chemical companies
Involvement in production or distribution of specialty cements / low-

temperature asphalt
producing/distributing specialty cements (a type of cement which have
other quality specifications, including low-temperature asphalt or low-
sulfur content).
a) No Value

f) No involvement
• Keyword(s):
Low-temperature, low temperature, asphalt, low sulfur, low-sulfur
- Score based on involvement in producing/distributing low-
temperature asphalt. Example: Most likely found in Construction
companies and chemical companies
Involvement in production or distribution of insulation materials

manufacturing insulation materials
a) No Value
f) No involvement
• Keyword(s):
Insulation material, insulation, mineral wool, various fibers, foam, or
fiberglass
- Score based on involvement in manufacturing insulation materials
like building products and chemicals.
Involvement in production or distribution of low toxicity/VOC materials

producing low toxicity/low VOC or VOC free chemicals
a) No Value
f) No involvement
• Keyword(s):
Low toxic, low-toxic, VOC, Volatile organic compound, paint, coating,
adhesive
- Score based on involvement in producing low toxicity/low VOC or
VOC free chemicals like paints/coatings/adhesives.

Involvement in production or distribution of FSC-certified lumber

production of FSC-certified lumber/sustainable agro-forestry
a) No Value
f) No involvement
• Keyword(s):
FSC, Forest Stewardship Council, lumber, wood, forest
- Score based on involvement in production of FSC-certified
lumber/sustainable agro-forestry

Transitional Energy
Extent of involvement in clean coal
clean coal development/production
a) No Value
f) No involvement
• Keyword(s):
Coal, clean coal
- Score based on involvement in clean coal development/production
Extent of involvement in nuclear energy

nuclear energy development/production
a) No Value
f) No involvement
• Keyword(s):
Nuclear, nuclear energy, energy
- Score based on involvement in nuclear energy
development/production
Practices - Strategy
Strategic focus on clean technology development
• Definition: This data point refers to the breadth and strength of the
company’s strategy to specifically develop clean technologies, not overall
technology development strategy. Most companies in this industry have
comprehensive strategies addressing cutting-edge technology
development, while few leading companies have a clear focus on clean
technology development
a) Cleantech innovation is the core strategy
b) Cleantech innovation is among key strategic objectives
c) Some initiatives in cleantech innovation
d) Not disclosed
• Keyword(s):
Clean technology, clean tech, technology
- These are usually found in the first pages in the CSR or websites
(usually included with the mission/vision/goals). Valid disclosures
include (but not limited to):
o Statements of the company’s business strategy before
going to their specific product lines
o Disclosures on the company’s plans to expand their
business towards eco-friendly products/clean technology
o CEO statement on the overarching clean technology
strategy/initiatives
o Outlines in their AR reports on the clean technology R&D
initiatives the company are currently engaged in
- Not many companies would disclose R&D allocation yet. Do not
consider this as the only criteria if company is not disclosing R&D
on specific clean tech. Cleantech R&D allocation can still be used
as alternate criteria but also only for those with disclosures only.
High R&D allocations will be more applicable to manufacturing or
technology companies
- Scoring:
o Cleantech innovation is the core strategy = clean tech is a
core business line or a core focus for future technology
development; or clear business strategy or explicit plan to
invest substantial amounts of R&D expense in clean tech to
drive the business growth; or dedicated business direction
from executive management (e.g., GE’s Ecomagination
program). If disclosure on R&D allocation is available: over
20% of R&D allocation into the business segment that
produce clean tech
o Cleantech innovation is among key strategic objectives =
Identifies some opportunities, with intentions of making
cleantech one of (several) key strategic objectives. If
disclosure on R&D allocation is available: below 20% of R&D
allocation into segment that produces clean tech products
o Some initiatives in cleantech innovation = scattered clean
tech products that have not developed into main business
lines or plans to invest in clean tech R&D initiatives. If
disclosure on R&D allocation is available: below 10% of R&D
allocation to clean tech
o Not disclosed = no involvement in clean tech

Industry Guidelines
o There are no R&D activities for this industry because they do
not manufacture/innovate products
o Trading companies/distributors are more like enablers of
cleantech rather than developers of the technology, hence,
R&D allocation should not be the basis of scoring this
datapoint for this industry
Targets to increase investment in clean tech

• Definition: This data point refers to the extent to which a company has a
strategy to develop new environmental technology and a target to increase
investment in R&D initiatives, sales in clean tech markets, or human capital
dedicated to clean tech development
a) Yes
b) Not disclosed
• Keyword(s):
Clean technology, clean tech, technology
- This data point should be strictly for disclosures with clearly
defined targets, meaning, the target is time-based and provides
quantitative investment in USD (exception: Trading & Distributors
Industry; see industry guidelines).
- Be careful on disclosures that says the goal to increase "sales" of
this cleantech product. It should not focus on sales, because we are
looking at how much investment the company is willing to make to
create newer cleantech products from their existing portfolio.
o Some disclosures that we consider is when the company
says, for example, they are planning to increase their budget
for R&D (should be for a specific clean technology) up to
30% increase from FY2020, by 2025
- Scoring:
o Yes = a company provides quantitative revenue targets
(exception: Trading & Distributors Industry; see guidelines),
R&D initiatives focused on clean tech products
development, explicit plans to expand current business
lines into clean tech areas. Do not consider if only revenue
targets on certain clean tech are disclosed. There should be
quantitative R&D investment targets for the same cleantech
Not Disclosed = a company provides no evidence, narrow

o
business focus on one or two business segments or
products
Industry Guidelines
- Sector/Industry/Sub-Industry: Chemicals Industry (sub-industries -
Diversified Chemicals, Commodity Chemicals, Specialty Chemicals,
Industrial Gases, Fertilizers & Agricultural Chemicals)
o Quantitative target on "eco-products" sales OR R&D devoted
to cleantech are ALLOWED
o Disclosure MAY BE QUALITATIVE
o Common disclosures:
• Statements that mention that the company will add
products that are energy efficient as part of their
plans
• Statements on acquiring companies that are
distributing eco-friendly products
Practices – Programs & Initiatives

Number of patent families
• Definition: This data point refers to the number of patents the company
has
N/A; this is a free text
• Keyword(s): patent
- Look for patents by the company. This data point could possibly
change every few years if company lose their patents or obtains
more patents.
- If the company only disclosed an estimate number of patents and
there are no other evidence/disclosure of the exact value, use what
was disclosed by the company and indicate in the Internal Notes
that the value is only an estimate as reported
Opportunities in Green Building

to develop/refurbish buildings with lower embodied energy, recycled materials, lower
energy/water use, waste reduction, and healthier environments. Scores are based on
green property initiatives, tenant engagement and urban site criteria; certified
properties; and environmental performance.
Applicable guidance across the KI:

• Sustainability practices that only apply to the office/corporate
headquarters should not be considered. (Note: This is applied to all sub-
industries)
• For Real Estate Services (RES) companies don’t typically own a real estate
portfolio, however, datapoints pertaining to portfolio do not have to be “no
value”, because certifications/ green investment efforts in their client’s
portfolio or in their listings should be considered
Green Property Investment

Evidence of green building commitment or target
• Definition: This data point refers to evidence of green building
commitment or target
(a) Yes
(b) No
(c) Not Disclosed
(d) No Value
• Keyword(s):
“Certif", "Energy", "water", “efficient,” "carbon", “environment,” “sustaina,”
“waste”, “light”, “green buildings”, “green”, “LEED”, “BREAM”
- Check the Green Building Certification Standards at the end of this
document for a NON-EXHAUSTIVE LIST of acceptable and non-
acceptable green building certifications.
- Scoring:
o Yes – Applicable if a company has one or more certified
properties in its portfolio or the company implements non-
certified green building investments in one or more of its
properties.
o No – Applicable if the company does not have certified
properties in its portfolio or does not mention any
investment on non-certified green building features in its
properties. * If no evidence scored this as “No” instead Not

disclosed. *
- If you see a certification that is NOT listed, please email
real_estate_esg@msci.com, dcs_realesate_esg@msci.com.
Green building commitment extends to existing buildings in portfolio (in

addition to new buildings)
• Definition: This data point refers to green building commitment extending
to existing buildings in portfolio
(a) Yes
(b) No
(c) Not Disclosed
(d) No Value
• Keyword(s):
“Refurbish,” “Redevelop,” “Upgrade”,” Renovat”
- Scoring:
o Yes – Applicable if the company renovates its existing
properties using green building features, even if these
features are not certified.
o No –Applicable if the company provides no evidence of
renovating its existing properties using green building
features.
- Note: It is important to highlight that in some cases, redevelopment
relates strictly to demolishing the existing property and building one
anew. In this case, even if it is an existing land plot, it is not an existing
property. Hence, we do not count this type of redevelopment as a “yes”.
Extent of green building certification commitments

• Definition: This data point refers to the extent of green building
commitments
(a) Yes
(b) Substantial
(c) Average
(d) No
(e) No Value
• Keyword(s):
“Certif", "Energy", "water", “efficient,” "carbon", “environment,” “sustaina,”
“waste”, “light”, “green buildings”, “green”, “LEED”, “BREAM”
- Scoring:
Yes – Applicable if, and only if, a company explicitly states
o
that it invests in green building features in a 100% of its
portfolio, regardless of whether these investments are
certified.
o Substantial – Applicable if the company provides evidence
that it invests in green building features across its portfolio,
but there is no explicit mention that these investments apply
to a 100% of the company’s properties (No specific scope).
The current option is valid regardless of whether these
investments are certified.
o Average – Applicable if the company provides evidence that
investment in green building features happens in its
portfolio, regardless of the proportion of the company’s
portfolio in which they happen or whether they are certified.
*This is more like a general statement*
o No – Applicable if the company provides no evidence of
green building investments in its property portfolio.
Level of green building commitment relative to country standards

• Definition: This data point refers to the level of green building commitment
relative to country standards
(a) Highest
(b) Average
(c) Minimum or Unknown
(d) No Value
• Keyword(s):
"Certif", "Energy", "water", “efficient,” "carbon", “environment,” “sustaina,”
waste, light, standard
- Check the Green Building Certification Standards at the end of this
document for a NON-EXHAUSTIVE LIST of acceptable and non-
acceptable green building certifications.
- Scoring:
o Highest – Applicable if the company already has
implemented or has only made the commitment for having
all refurbishments and all new developments (100%) to be
certified to the top two levels of a green building
certification standard (e.g., LEED Platinum or Gold; BREEAM
Outstanding or Excellent; EnergyStar; 6 or 5 GreenStar;
NABERS Energy 6 or 5; BER level A or B for property
operators; BER level A1 for homebuilders/residential
developers).
o Average – Applicable if the company already has
implemented or only has made the commitment for having
some refurbishments or some new developments (any
percentage lower than 100%) to be certified to any level of
a green building certification standard.
o Minimum or Unknown – Applicable if the company has not
implemented or has not made the commitment for having
any refurbishment or any new developments to be certified
to green building certification standard.
o No value
Property portfolio performance relative to peers based on a national

mandatory Green Building rating system
• Definition: This data point refers to the company's property portfolio
performance relative to peers based on a national mandatory Green
Building certification or rating system
(a) Above average
(b) Average
(c) Below average

(d) No Value
• Keyword(s):
Search using the NON-EXHAUSTIVE LIST of acceptable and non-
acceptable green building certifications
- This procedure will be followed for RES companies that manage their
own or client’s property portfolio.
- This data point is applicable if a company has a non-residential
property located in Australia, or a non-residential or residential property
located in the UK, in any of the EU member states, or in Ireland, or in
China.
- If above criteria apply to the company but there is no disclosure on
mandatory green building rating system specified below, then select
the lowest score ‘Below Average’.
- This also looks at the majority of the portfolio
o if more than 50% of a UK company’s non-residential and
residential portfolio has an EPC of C, then ‘Above average’
score must be given.
- If not applicable, then select ‘No value’.
- Scoring:
Dropdown Choice Above average Average Below average No Value
NABERS Energy
NABERS Energy NABERS Energy rating
AUSTRALIA higher than 3.5 Applicable if the company’s
rating of 3.5 Stars lower than 3.5 Stars
Stars properties are not of the
mentioned types and are not
UK/ANY EU MEMBER EPC rating of C or EPC rating lower than located in any of the
EPC rating of D
STATES higher D mentioned regions
IRELAND BER level A or B BER level C BER level lower than C
Select this also if there are
IRELAND - no disclosures on respective
BER level lower than
HOMEBUILDERS/ BER level A1 BER level A2 or A3 mandatory
A3
RESIDENTIAL DEVELOPERS certification/ratings but has
other green building
Green Star Level 1 or certifications
CHINA Green Star Level 3 Green Star Level 2
below
For example, if an Irish homebuilder does not disclose anything on BER, but has
other certifications such as LEED, you would score it as ‘No value’.
Description of non-certified green building efforts

• This will be only updated by the Content Analyst
• Transfer all data in Internal Notes
• Continue researching and just keep the notes and data sources in internal
notes section.
Tenant and property manager engagement

Extent of commercial arrangements to improve or maintain property
environmental performance
• Definition: This data point refers to the extent of commercial arrangements
to improve or maintain property environmental performance
(a) Commercial agreements to incentivize tenants and property managers
to improve property performance
(b) Tenant or property manager engagement without commercial
agreements
(c) No Value
• Keyword(s):
“Program”, “submeter”, “engage”, Fit-out, “space”, “warrant”
- Scoring:
o Commercial agreements to incentivize tenants and
property managers to improve property performance –
Applicable if the company provides evidence on
implementing commercial agreements (i.e., not linked to
the lease execution such as green or triple lease, but that
imply a bilateral pact between the property owner and the
property dweller(s). For homebuilders and residential
developers, this KPI relates to after-sale agreements
between homeowners and developers.
o Tenant or property manager engagement without
commercial agreements – Applicable if the company
provides evidence on implementing engagement or
educational programs (i.e., a unilateral offering from the
property). For homebuilders and residential developers, this
KPI relates to after-sale engagement programs offered by
homeowners and developers.
• Definition:
- Commercial agreements are bilateral non-legally binding programs not
linked to the lease execution between property owners and property
dwellers that look for conserving resources, ensuring the efficient
operation of buildings, and, indirectly, saving money and improving
returns on investments. Commercial agreements usually encompass
one or more of the following waters, waste, and energy metrics.
- A fit-out is the name of the construction that shapes tenants’ interior
spaces, which is different from the actual structure in which the fit-out
is built. A classic example would be a retail mall in which there are

stores of different sizes. Imagine two stores of the same size in that
mall, but one selling shoes and the other one being used as a bank. The
fit outs (interiors) would be radically different for each of them.
- Submetering relates to the practice of having each tenant paying the
utilities’ costs for the space they use instead of having a global meter
for the utilities for the whole property. For the former, tenants have the
incentives to become more resource efficient, as they are internalizing
the exact costs and savings of their utility’s usage. On the latter, tenants
do not have this incentive, as global utilities’ costs are typically prorated
between the total number of tenants in the property and this cost
become a fix item included in lease payments.
Green or triple net leases

• Definition: This data point refers to green or triple net leases
(a) Yes
(b) Not disclosed
(c) No Value
• Keyword(s):
Green, “leas”, triple, clause, “Performance based lease”, “aligned leases",
"high performance leases", "energy efficient leases" or leases with "green
provisions" or "green addendums".
- Scoring:
o Yes – Applicable if the company provides evidence on
implementing green leases or triple net leases among its
tenants.
o Not disclosed – Applicable if the company provides no
evidence on implementing green leases or triple net leases
among its tenants.
o No value – Applicable for homebuilders and residential
developers that have no involvement in leasing properties.
• For Real Estate Services (RES)
- Scoring:
o Yes – Applicable if the RES company provides evidence on
implementing or facilitating green leases or triple net leases
on behalf of clients
• Definition:
- The implementation of green leases addresses in a legally binding way,

between property dwellers and property owners, behavioral changes
that contribute to reap the benefits of investing in green features by
decreasing operational and maintenance expenses. These expenses
are related to water and energy consumption, and waste management.
However, green leases typically encompass only energy efficiency.
In other words, green leases create contractual obligations with

specific performance metrics between property owners and
tenants so they can work together to conserve resources, ensure
the efficient operation of buildings, and, hence, save money and
contribute to improving returns on investments.
- A triple-net lease is a lease agreement on a property where the tenant

agrees to pay all real estate taxes, building insurance and maintenance
on the property in addition to fees related to rent, utilities, etc. In such
a lease, the tenant is responsible for all costs associated with the repair
and maintenance of any common area. This type of leases gives
tenants the incentives to become as efficient as possible by identifying
inefficient practices, investing in upgrades, and reaping the benefits of
those investments in the form of lower costs from running the property.
Green leases as percentage of total leases

• Definition: This data point refers to percentage of green or triple net leases
• Keyword(s):
Green, “leas”, triple, clause
- Record the percentage of the green or triple net leases from total
leases.
- Not Applicable to homebuilding and other residential developers
- Scoring:
o Not applicable for RES companies unless they manage their
own portfolio or have an investment management segment
where they manage clients’ property portfolios.
o For RES companies that manage their own or their clients’
property portfolios:
• Input data if the RES company provides a
percentage or factors to calculate this percentage of
the green leases from its total leases.
Urban site investment criteria

Evidence of flexible / mixed use properties
• Definition: This data point refers to evidence of a mixed-use property,
which that defines is a property which has with multiple use classes for
different floors or areas of the building, e.g., commercial, retail, and/or
residential, etc.
• Dropdown Choice:
(a) Yes
(b) Not disclosed
(c) No Value
• Keyword(s):
Mix, flex
- Not applicable to homebuilding and other residential developers,
unless they develop or manage non-residential properties
- Scoring:
o Yes – Applicable if the company provides evidence of
property with a mixture of uses or multiple use classes in its
portfolio.
evidence of mix or flex-use properties in its portfolio.
- Note: Sometimes this evidence is not explicit from the keywords but if
you come across property pics or wordings (such as “this office
building has a retail space”) it is valid to justify a “yes”. This alternative
of researching this data point is not mandatory.
Evidence of urban revitalization / urban redevelopment

• Definition: This data point refers to urban revitalization / urban
redevelopment
(a) Urban revitalization
(b) Infill development or urban redevelopment
(c) No Value
• Keyword(s):
“redeve”, “revit”, “renew”, “rebuild”, “reconst”, “remodel”, “regeneration”,
neighbor/community
- It is important to highlight that this data point relates to both
demolishing and constructing new buildings, as well as renovating
existing buildings, in urban settings
- The difference with “infill development or urban redevelopment” and

“urban revitalization” also relates to scale, as
o infill developments and redevelopments happen mostly in
plots where only one property existed, or it is currently
abandoned.
o Urban revitalization refers mostly to reviving economically
depressed or abandoned entire neighborhoods of cities.
- Scoring:
o Urban revitalization – Applicable if the company provides
evidence of initiatives aimed at improving existing features
of the urban environment or reorganizing an existing city
structure, particularly in neighborhoods in decline due to
economic or social reasons. Urban revitalization initiatives
generally include improving features of the urban
environment, such as the quality of pavement and the
functionality of the sidewalks. The projects can also address
the need for improved community engagement and
occupation of the public spaces.
https://pppknowledgelab.org/sectors/urban-revitalization
o Infill development or urban redevelopment – Applicable if
the company provides evidence of development of
underused or vacant land in existing urban areas to increase
density and place new development near existing resources
and infrastructure.
https://www.planetizen.com/definition/infill-development.
- Scoring:
o Urban revitalization – Applicable if the RES company
provides evidence of large-scale redeveloping or
revitalizing. Applicable also if its own or its clients’ portfolio
includes properties that are part of large-scale urban
redevelopment or revitalization projects.
o Infill development or urban redevelopment – Applicable if
the RES company provides evidence of infill development or
urban redevelopment. Applicable also if its own or its
clients’ portfolio includes properties that are part of infill
development or redevelopment projects.
Evidence of urban brownfield redevelopment

• Definition: This data point refers to urban brownfield redevelopment
(a) Yes
(b) Not disclosed
(c) No Value
• Keyword(s):
Brown, field, “contaminat”, remediate
- A brownfield is a previously developed site that its soil has been
contaminated and in which environmental remediation must be
conducted to clean the site from pollutants.
- Scoring:
having properties on or of redeveloping previously
contaminated sites (brownfields).
evidence of having properties on or of redeveloping
previously contaminated sites (brownfields).
- Scoring:
o Yes – Applicable if the RES company provides evidence of
having properties on or of redeveloping previously
contaminated sites (brownfields), whether for its own or its
clients’ portfolio. Applicable also if its own or its clients’
portfolio includes properties that are part of brownfield
redevelopment projects.
Commitments related to greenfield developments (land bank, farm land,

green field, agricultural land)
• Definition: This data point refers to commitments related to greenfield
developments (land bank, farmland, green field, agricultural land)
(a) Clear statement on avoiding greenfield development
(b) Developing only green-certified properties in greenfields development
(c) Evidence of non-green certified greenfield growth
(d) Not disclosed
• Keyword(s):
Green, field, land, farm
- A greenfield is a site that has never been developed before.
- Scoring:
o Clear statement on avoiding greenfield development –

Applicable if the company provides evidence of having a
commitment to avoid green field developments.
o Developing only green-certified properties in greenfield
development – Applicable if the company provides
evidence of having a commitment to develop only green-
certified properties when developing in green fields.
**PLEASE NOTE: these certifications should be “design
certifications”, which mean that they take into consideration
a category on sustainable sites (such as LEED, BREEAM,
CASBEE, etc.). Energy Efficiency only, Water Efficiency only,
Indoor Environmental Quality only certifications, do not
count. Please see the appendix to find the one-dimensional
certifications that do not count for this KPI).
o Evidence of non-green certified greenfield growth –
Applicable if the company provides evidence of having or
planning green field developments that are not green-
certified.
evidence of having a commitment to avoid green field
developments or green certifying their properties in
previously undeveloped land.
Evidence of affordable residential properties

• Definition: This data point refers to affordable residential properties
(a) Yes
(b) Not disclosed
(c) No Value
• Keyword(s):
Low, income, price, social, elder, aging, senior, public, temporary, “afford”,
“access”
- Not applicable to non-residential properties’ managers or developers,
with exception to those that have residential properties in their
portfolios - choose ’No Value’.
- Scoring:
managing or developing residential properties for social or
public housing, low-income populations, elderly, managed
under social rent or purchased through shared equity or
shared ownership. In general, this definition includes

housing options, either homeownership or home rental, in
which the household living there does not devote more than
40% of its available income. This definition excludes,
however, high-income households.
evidence of managing or developing residential properties.
- Scoring:
dealing in (whether for its own or its clients’ portfolio)
residential properties for social or public housing, low-
income populations, elderly, managed under social rent or
purchased through shared equity or shared ownership. In
general, this definition includes housing options, either
homeownership or home rental, in which the household
living there does not devote more than 40% of its available
income. This definition excludes, however, high-income
households.
Evidence of affordable commercial properties

• Definition: This data point refers to affordable commercial properties
(a) Yes
(b) Not disclosed
(c) No Value
• Keyword(s):
Low, income, price, social, small medium enterprises, public, “afford”,
“access”
- Not applicable to homebuilding and other residential developers, with
exception to those that have non-residential properties in their
portfolios - choose ’No Value’.
- Scoring:
managing or developing non-residential properties targeting
to Small and Medium Enterprises (SMEs), micro enterprises,
local community business or businesses owned or targeted
to communities that have been historically marginalized or
in disadvantage, and to low-income population.
Not disclosed – Applicable if the company provides no

o
evidence of managing or developing non-residential
properties.
- Scoring:
dealing in (whether for its own or its clients’ portfolio) non-
residential properties targeting to Small and Medium
Enterprises (SMEs), micro enterprises, local community
business or businesses owned or targeted to communities
that have been historically marginalized or in disadvantage,
and to low-income population.
Performance
Total portfolio (number of buildings)
• Definition: Company provides the total count of the properties it manages
or develops.
• Keyword(s):
“Prop”, portfolio, build, area, sq, square, mt, meter, feet, foot
- Check the new Guidance - Total Portfolio and Green Building
Certifications
- Applicable if the company provides the total count of the properties, it
manages or develops.
- NOTE: Don’t count number of projects but number of buildings
- For Real Estate Services (RES)
• Input data if the company provides the total count of
the properties, it manages or develops.
o Office/corporate headquarters should not be considered
Commented [ACJ73]: This procedure can be used
under this data point while profiling.
o Pure play residential managers or developers usually
report number of units, as they manage multifamily Pending to Content Team:
developments. If it is possible to identify the number of Only example of issuers is pending.
units that have been certified, then it is fine to have the total
Commented [LRA74R73]: Content to provide sample
for this?
portfolio in number of units. Otherwise, having the portfolio

in number of buildings is more practical.
o The portfolios of hotels, hospitals or retirement
communities should have an analogous treatment as
described in the note above for the same reasons.
o For the case of homebuilders, they usually report number of
houses, typically single family regardless, if these properties
are stand-alone or attached one after the other. In this case,
do include number of properties built per year.
-
Total portfolio (in million sqf)

• Definition: Company provides the total surface of the properties it
manages or develops.
• Keyword(s):
- For China/ Hong Kong: GFA, sqm
- Applicable if the company provides the total surface of the properties,
it manages or develops.
- For China/ Hong Kong:
o check annual report section (Management discussion and
analysis, or a standalone page of appendix named for major
property list)
• Input data if the company provides the total surface
of the properties, it manages or develops.
under this data point
- Scenario:
There is some evidence of green building certification

• Definition: This data point refers to the evidence of green building
certification
(a) Yes
(b) No
• Keyword(s):
- This datapoint should always be answered regardless of if other
performance fields are left blank.
- Scoring:
managing or developing green certified properties in its
portfolio, but it is not possible to establish the total number
of these properties. In case there is quantifiable evidence of
GB certifications, please select this indicator as well.
o No – Applicable if the company provides no evidence of
managing or developing green certified properties in its
portfolio.
- Scoring:
promoting or supporting clients in acquiring GB
certifications. In case there is evidence of GB certifications
for its own or its clients’ portfolio, please select this option
as well.
o No – Applicable if the RES company provides no evidence
of practices stated above.
- Office/corporate headquarters should not be considered under this
data point
Number of green certified buildings in portfolio

Number of certified Green Buildings in portfolio according to company
disclosure
• Definition: This data point refers to the number of certified green buildings
in the company's portfolio
• Keyword(s):
Certifications
- Applicable if the company provides the total count of the green certified
properties, it manages or develops.
- Note: Some companies have concurrent green building certifications,

i.e., LEED certified buildings could be also EnergyStar buildings or could
have an ISO 14001 certification. Make sure that you do not double
count these certifications.
• Input data if the company provides the total count of
the properties, it manages or develops.
under this data point.
o Note: For the case of highly diversified portfolios, where Commented [ACJ75]: This procedure can be used
there are retail, office, hotel, residential, industrial, etc., while profiling.
properties, the ideal is to use Net Asset Values (NAV) to
estimate the percentage of the portfolio certified to a Pending to Content Team:
Only example of issuers is pending.
green building standard. This is typically the case for
Health Care REITs in the US, in which companies
themselves provide this NAV itemization. However, if this
is not possible, then use number of buildings or number of
communities, in the case of retirement communities, or
portfolio surface to calculate the percentage of the
certified portfolio. For these cases, it is acceptable to
overwrite the green certified percentage.
Number of green certified buildings in portfolio according to other sources

(e.g. national database)
• Definition: Indicates the Number of green certified buildings in
portfolio according to other sources.
• Keyword(s):
Certifications
- Applicable if the national register, local green building council or other
reliable source, provides the total count of the green certified properties
a specific company manages or develops.

Green certified space (in million sqf)

Total square footage of certified Green Buildings in portfolio according to
company disclosure (in million sqf)
• Definition: This data point refers to the total square footage of certified
green buildings in the company's portfolio
• Keyword(s):
"Certif", LEED, BREAAM, EnergyStar, etc.
- Applicable if the company provides the total surface of the green
certified properties it manages or develops
- Note: Some companies have concurrent green building certifications,
i.e., LEED certified buildings could be also EnergyStar buildings or could
have an ISO 14001 certification. Make sure that you do not double
count these certifications.
Total square footage of green certified buildings in portfolio according to

other sources (e.g. national database)
• Definition: Indicates the total square footage of green certified buildings in
portfolio according to other sources
• Keyword(s):
"Certif", LEED, BREAAM, EnergyStar, etc.
- Applicable if the national register, local green building council or other
reliable source, provides the total surface of the green certified
properties a specific company manages or develops.
Guidance - Total Portfolio and Green Building Certifications:

Scenario 1: If there is updated data for Total Portfolio but no update for Number of
Green Certifications
▪ We can update the Total Portfolio and retain the figure for certifications, if we
can verify that those certified properties are still in the company's portfolio.
Total Portfolio Number of green certified buildings in portfolio
(number of buildings)
FY 2021 FY 2020
100 10
▪ If it has been 2 years and still no updated data on certifications AND we cannot
verify if the last disclosed certified properties are still in the company's
portfolio, then we can remove the figures under certifications.
FY 2021 FY 2019
100 10 -> This should be removed if we cannot verify
Scenario 2: If there is updated data for Number of Green Certifications but no clear
or update on Total Portfolio
▪ We can still input certification figures but leave total portfolio blank.

No clear data even in previous FY 2021
assessments -> leave as blank 10
▪ If there is outdated total portfolio data, do not update certification figures until
we have BOTH updated figures for Total Portfolio and Number of Green
Certifications. Ensure similar “as of dates”/ ”fiscal years” for Total Portfolio
and Number of Green Certifications data.
FY 2020 FY 2020
100 10
If there is available disclosure
FY 2021
20
Note: Retain the old value of FY 2020. To ensure same fiscal year as the Total
Portfolio.
As of Dec 2021 As of March 2022
100 10
Note: we can input IF WE CAN VERIFY THAT THERE WAS NO CHANGE IN PORTFOLIO
SINCE DEC 2021 (no property sold or acquired). If unsure, leave as blank.
NON-EXHAUSTIVE LIST OF GREEN BUILDING CERTIFICATIONS

Criteria for inclusion of Certifications
1. The certification must be granted by a recognized and independent
third party.
2. The certification must include energy efficiency requirements; and,
3. The certification must clearly state how a building certified with its label
compares to a conventional building.
Green Building Standard Origin
Building Environmental Assessment Method Hong Kong
(BEAM)
*BELS (Building Energy-efficiency Labeling Japan
System)
BOMA BEST Canada
BOMA 360
BREEAM United Kingdom
CASBEE Japan
Green Building Evaluation Label or China Three China
Star (All levels considered “green certified”)
Development Bank of Japan (DBJ) Green Japan
Building Certification
DGNB Germany
EDGE International Finance Corporation
*Energy Star United States
Green Building Index Malaysia
Parksmart (formerly known as Green Garage United States
Certification)
Green Globes (Levels 4 and 5 only) Canada
Green Key Denmark
Green Mark Singapore
Green Star Australia
Green Star SA South Africa
GRIHA (Green Rating for Integrated Habitat India
Assessment)
HQE (Haute Qualité Environnementale) France
Homestar New Zealand
IGBC India
Leadership in Energy and Environmental Design United States
(LEED)
Living Building Challenge United States
*Minergie Switzerland
*NABERS (must be equal or higher than 3.5 Australia
stars)
ICC 700 National Green Building Standard United States
(NGBS)
Qualiverde Brazil
Pearl Rating System for Estidama (must be United Arab Emirates
equal or higher than 2 pearls)
Superior Energy Performance 50001 United States
The Sustainable SITES Initiative United States
Miljöbyggnad Sweden
Passive House (Passivhaus) Sweden, Germany
*GreenBuilding Sweden
KfW Efficiency House 40, 40 plus, and 55 Germany
*Energy Performance Certificates (EPC) A and EU, UK

B ratings only
*Building Energy Rating (BER) Ireland
For operators, A and B levels only
For homebuilders/residential developers, A
level only
G-SEED South Korea
WELL Building Standard
Fitwel
*Arc Energy Performance Certificates
CALGreen (Tiers 1 and 2 only)
*Tokyo Low-Carbon Small and Medium-Sized Tokyo Metropolitan Government
Model Buildings (TMG)
*One-dimensional valid certifications, as they focus on energy
Those in blue are changes as of March 2022
Those in yellow are changes/updates as of May 202
LIST OF NON-ACCEPTED GREEN BUILDING CERTIFICATIONS
Green Building Standard Origin Reason of exclusion
TripAdvisor GreenLeaders United States
Maryland Green Travel Partner United States
Florida Green Lodging
United States
Program
Standard Assessment
United Kingdom
Procedure (SAP)
IREM makes no guarantee on the
actual sustainability performance of
a certified property at any particular
IREM Certified Sustainable time, and IREM takes no
United States
Property (CSP) responsibility for claims about
property performance, value, or
insurability based on certification
under the IREM CSP program.
Excluded as of March 2022:
BEE (Bureau of Energy not in GRESB's list/ limited details on
India
Efficiency) certification/ certification is not
widely used
not in GRESB's list/ limited details on
CALENER Spain
certification/ certification is not
widely used

Green Globe United States
widely used
Green Standard Russia
widely used
ISO 14001 Switzerland more on management than property
performance
performance
performance
Denmark, Finland, Excluded as of March 2022:
Nordic Ecolabelling Iceland, Norway, more applicable to products, not
Sweden buildings
Those in blue are changes as of March 2022
Opportunities in Nutrition Health

This issue evaluates the extent to which companies take advantage of growth
opportunities in the market for healthier products. Scores are based on exposure to
geographies with strong demand for healthier products; innovation capacity; and
products with an improved nutritional or healthier profile (including credible external
verification).
Applicable guidance across the KI:

For Household & Personal Products Sector – Opportunities in Nutrition Health was
discontinued.
Except for Consumer Staples and Restaurants, please ensure to check the
company’s website or online groceries stores/any online stores of the company
on what products they offer to consumers. For example, some food retailers are
offering personal/household products, then the datapoints under personal
products/cosmetics or household products could be scored.
NOTE: For groceries stores, there is a limited information on granular disclosures

when it comes to these products. So, this is usually scored Begun commercial
sales but low revenue (less than 5% of revenues). However, if the company
discloses that they are private label brands composed of Healthy Brands (e.g.,
Healthy Options) or they sell a lot of healthy products and private label brands
composed more than 5% of the revenue, then we could credit higher than 5%.
Practices
Strategy that encompasses development of natural and healthy products
• Definition: This data point refers to the company's strategy the
encompasses development of natural and healthy products.
(a) Yes
(b) Some initiatives
(c) No
• Keyword(s):
healthy, healthy products, Fat-Free, Low-Fat, Low-Sugar, Unsweetened,
Low-Salt, Low-Sodium, Salt-Free, Sugar-Free, Organic, Plant based, meat
alternatives
- Identify if the company adopted a technology development strategy

that encompasses more natural and healthy products.
- Scoring:
o Yes – if the company improved nutritional/ health profile of
most products as part of core strategy, has targets, and
strong R&D.
• Note: Consider if the disclosure is more than 20% of
revenue coming from healthy food products and
with quantitative target to increase healthy food
product offering
o Some initiatives – Some evidence / initiatives of
development of products that are responding to the growing
demand for healthier products, general commitment of
improvement.
o No – If a company is into food manufacturing business but
they are not at all into selling Healthy or Natural product
ranges
- Ex. "Increase the share and availability of healthy products in our
assortment and provide information to facilitate healthier and more
sustainable diets for our customers and associates. Our approach
We aim to make healthier eating commonplace. By making fresh,
nutritious, and delicious food available and affordable for everyone,
we contribute to healthier communities."
In-house innovation capacity (e.g. research centers and staff)

• Definition: This data point provides information if the company has a
dedicated research team or center that develops more natural and healthy
products.
(a) Extensive in-house research
(b) Limited
(c) None
• Keyword(s):
Research, research and development,
- Some companies have a section in AR, CSR or Company Website
that disclose Nutrition Initiatives
- Scoring:
o Extensive in-house research –
• company must have clear quantitative disclosure on

the investment in R&D and it should be focusing on
nutrition health
• in-house expert and third-party nutritionist/dietitians
• company disclose that they have research hub
focusing on H&N and
• they have number of staff or personnel that focusing
on H&N with guidance from the external
stakeholders.
o Limited – Some investment in Health & Nutrition at the R&D
level, or evidence of in-house experts
(nutritionist/dietitians) dedicated to H&N
• At least 30% of the Consumer Staples companies
usually disclose that they have in-house experts
(nutritionist/dietitians) dedicated to H&N but they
don’t receive information or some R&D help from
external stakeholders. In addition, if the company
don’t have an internal research hub wherein, they
cannot formulate their products but they have that
capacity.
o None – Nutrition and Health does not appear a strong R&D
focus, no evidence of in-house research staff dedicated to
H&N issues
Food & Beverage

Company produces or markets food products
• Definition: This data point provides information if the company produces
or sells food and beverage products.
(a) Yes
(b) No
(c) Not Disclosed
• Keyword(s):
Food, Packaged Food, Frozen Products
- only applicable for food industries. No value for other sectors
- The scoring for this data point will either be “Yes,” “No,” or “No
Value”
- Scoring:
o Yes – If the company is into selling “Food Products”
o No – If the company is NOT into selling “Food Products”

-
NOTE: If a company is NOT into manufacturing, selling, or
marketing of food products, then the scoring for the above-
mentioned data point should be “No Value”
Extent of programs to reduce fat
• Definition: This data point provides information on the extent of programs
that company develops to reduce fat in their food and beverage products.
(a) Nearly all products covered
(b) Involvement as part of core business (more than 5% of revenues)
(c) Begun commercial sales but low revenue (less than 5% of revenues)
(d) R&D underway / exploring opportunities in the market
(e) No involvement
• Keyword(s):
Fat-Free, Low-Fat, Low-Sugar, Unsweetened, Low-Salt, Low-Sodium, Salt-
Free, Sugar-Free, Organic
- Select No Value if not applicable, instead of No or Not Disclosed
- If no data on % of revenues, very likely to represent less than 5%
- Scoring:
o Nearly all products covered – If a company’s most of the
product ranges or almost all the product ranges are Fat-Free
o Involvement as part of core business (more than 5% of
revenues) – If a company is into selling some Fat-Free or
Low-Fat Product ranges and they are getting more than 5%
of revenues from that segment
o Begun commercial sales but low revenue (less than 5% of
revenues) – If a company is into selling one or some Fat-
Free or Low-Fat product ranges
o R&D underway / exploring opportunities in the market – If
a company is into the Research & Development process for
making a Fat-Free or Low-Fat product but not yet available
in the market
o No involvement – If a company is NOT selling, marketing, or
manufacturing any Fat-Free or Low-Fat product ranges
Extent of programs to reduce fertilizers

that company develops to reduce fertilizers in their food and beverage
products.

(e) No involvement
• Keyword(s):
- Scoring:
product ranges or almost all the product ranges are
fertilizer-free
revenues) – If a company is into selling some Fertilizer-Free
Product ranges & they are getting more than 5% of revenues
from that segment
revenues) – If a company is into selling one or some
Fertilizer-Free Product ranges
making a Fertilizer-Free product but not yet available in the
market
manufacturing any Fertilizer-Free product ranges
Extent of programs to reduce sodium

that company develops to reduce sodium in their food and beverage
products.
(e) No involvement
• Keyword(s):

- Scoring:
product ranges or almost all the product ranges are Salt-
Free
revenues) – If a company is into selling some Salt-Free or
Low-Salt Product ranges and they are getting more than 5%
Sodium-Free or Low-Salt product ranges
making a Salt-Free or Low-Salt product but not yet available
in the market
manufacturing any Salt-Free or Low-Salt product ranges
Extent of programs to reduce sugar

that company develops to reduce sugar in their food and beverage
products.
(e) No involvement
• Keyword(s):
- Scoring:

product ranges or almost all of the product ranges are
Sugar-Free
revenues) – If a company is into selling some Sugar-Free or
Low-Sugar Product ranges & they are getting more than 5%
revenues) – If a company is into selling one or some Sugar-
Free or Low-Sugar product ranges
making a Sugar-Free or Low-Sugar product but not yet
available in the market
manufacturing any Sugar-Free or Low-Sugar product ranges
Extent of programs to increase offering of organic products

that company develops to increase offering of organic products.
(e) No involvement
• Keyword(s):
- Scoring:
product ranges or almost all the product ranges are Organic
revenues) – If a company is into selling some Organic
from that segment

revenues) – If a company is into selling of one or some
Organic Product ranges
making an Organic product but not yet available in the
market
manufacturing any Organic Food product ranges
Extent of programs to reduce artificial ingredients (e.g. preservatives,

colorings, aspartame, and other controversial ingredients)
that company develops to reduce artificial ingredients (e.g., preservatives,
colorings, aspartame, and other controversial ingredients) in their food and
beverage products.
(e) No involvement
• Keyword(s):
- Scoring:
product ranges or almost all the product ranges are free
from artificial colorings or preservatives
revenues) – If a company is into selling some Preservative-
Free or Coloring-Free Product ranges and they are getting
more than 5% of revenues from that segment
Preservative-Free or Coloring-Free product ranges
making a Preservative-Free or Coloring-Free product but not

yet available in the market
manufacturing any Preservative-Free or Coloring-Free
product ranges
Extent of programs to enhance or fortify products to address nutrient

deficiencies (e.g. vitamin A, zinc, iodine, iron)
that company develops to enhance or fortify products to address nutrient
deficiencies (e.g., vitamin A, zinc, iodine, iron).
(e) No involvement
• Keyword(s):
- Read the options carefully and choose the best option that describe
the company’s disclosure.
Scope of programs towards reducing portion size

• Definition: This data point refers to the company's scope of programs
towards reducing portion size.
(e) No involvement
• Keyword(s):

- Scoring:
o Nearly all products covered – If a company has reduced the
Portion Size from most of their product ranges or from
almost their entire product ranges
revenues) – If a company is into selling some Reduced
Portion Size Product ranges and they are getting more than
5% of revenues from that segment
Reduced Portion-Sized product ranges
reducing the portion size of any product but not yet available
in the market
o No involvement – If a company is not into the initiative of
reducing their product’s Portion Size
Personal Products / Cosmetics

Company produces or markets personal products or cosmetics
or sells personal products or cosmetics.
(a) Yes
(b) No
(c) Not Disclosed
• Keyword(s):
Personal Products, Shampoo, Conditioner, Moisturizer, Lotion/Cream, etc.
- only applicable for personal product/cosmetics industry. No value
for other sectors
Value”
- Scoring:
o Yes – If the company is into selling “Personal Products”
o No – If the company is NOT into selling “Personal Products”
- NOTE: If a company is NOT into manufacturing, selling, or

marketing of personal products, then the scoring for the above-
Extent of programs to increase offering of organic products

that company develops to increase offering of organic personal products /
cosmetics.
(e) No involvement
• Keyword(s):
Personal Products, Shampoo, Conditioner, Moisturizer, Lotion/Cream
- Scoring:
product ranges or almost all the product ranges are Organic
revenues) – If a company is into selling some Organic
from that segment
revenues) – If a company is into selling of one or some
Organic Product ranges
making an Organic product but not yet available in the
market
manufacturing any Organic Food product ranges
Extent of programs to reduce artificial or controversial ingredients

• Definition: Refers to the extent of programs to reduce artificial or
controversial ingredients

(e) No involvement
• Keyword(s):
- Scoring:
product ranges or almost the entire product ranges are free
from artificial or controversial ingredients
revenues) – If a company is into selling some artificial or
controversial ingredients-Free Product ranges and they are
getting more than 5% of revenues from that segment
product ranges that are free from artificial or controversial
ingredients
making a product that is free from artificial or controversial
ingredients but not yet available in the market
manufacturing any product ranges that are free from
artificial or controversial ingredients
Extent of programs to increase offering of products with more natural

vegetable based ingredients
• Definition: Indicates the extent of programs to increase offering of
products with more natural vegetable based ingredients
(e) No involvement
• Keyword(s):
- Scoring:
product ranges or almost the entire product ranges are of
more natural vegetable-based ingredients
revenues) – If a company is into selling some natural
vegetable-based product ranges and they are getting more
than 5% of revenues from that segment
product ranges that are more natural vegetable-based
ingredients
making a product that is more natural vegetable based but
not yet available in the market
manufacturing any product ranges that are more natural
vegetable based
Household Products
Company produces or markets household products
or sells household products.
(a) Yes
(b) No
(c) Not Disclosed
• Keyword(s):
Household Products, Detergent, Floor Cleaner, Kitchen Cleaner
- only applicable for household products. No value for other sectors
Value”
- Scoring:
oYes – If the company is into selling “Household Products,”

oNo – If the company is NOT into selling “Household
Products,”
- NOTE: If a company is NOT into manufacturing, selling, or
marketing of personal products, then the scoring for the above-
Extent of programs to increase offering of products with EU Eco Label or

third party equivalent
that company develops to increase offering of products with EU Eco Label
or third-party equivalent
(e) No involvement
• Keyword(s): Eco Label, EU Eco Label, Chlorine, Phosphates, Natural
- Scoring:
product ranges or almost all the product ranges are EU Eco
Label Based
revenues) – If a company is into selling some EU Eco label
product ranges and they are getting more than 5% of
revenues from that segment
revenues) – If a company is into selling one or some EU Eco
label product ranges
making an EU Eco Label household product but not yet
available in the market
manufacturing any EU Eco Label product ranges
Extent of programs to increase offering of products with more natural

vegetable based ingredients
that company develops to increase offering of household products with
(e) No involvement
• Keyword(s):
Eco Label, EU Eco Label, Chlorine, Phosphates, Natural
- Scoring:
product ranges or almost the entire product ranges are of
revenues) – If a company is into selling some natural
vegetable-based product ranges and they are getting more
than 5% of revenues from that segment
product ranges that are more natural vegetable-based
ingredients
making a product that is more natural vegetable based but
not yet available in the market
manufacturing any product ranges that are more natural
vegetable based
Extent of programs to reduce artificial or controversial ingredients (e.g.

phosphates, chlorine)
that company develops to reduce artificial or controversial ingredients
(e.g., phosphates, chlorine) in their household products.
(e) No involvement
• Keyword(s):
Eco Label, EU Eco Label, Chlorine, Phosphates, Natural
- Scoring:
product ranges or almost the entire product ranges are free
from artificial or controversial ingredients
revenues) – If a company is into selling some artificial or
controversial ingredients-Free Product ranges and they are
getting more than 5% of revenues from that segment
product ranges that are free from artificial or controversial
ingredients
making a product that is free from artificial or controversial
ingredients but not yet available in the market
manufacturing any product ranges that are free from
artificial or controversial ingredients
Opportunities in Renewable Energy

This key issue evaluates the extent to which companies take advantage of
opportunities linked to the development of renewable power production. Scores are
based on exposure to renewable power subsidies and preferential policies; strategic
investments in renewable power generation and related services; and renewable
capacity as percentage of total and trend.
Performance
Important Guidance on Current Total Installed Capacity (MW), Reported
Percentage, Reported MW, and Renewables and Hydro Capacity (% of total
capacity)
• Use the latest values from Exposure > Fuel Mix ONLY
• In case that the value from Fuel Mix was for the previous FY and there is
no data for the latest FY (E.g., latest data in Fuel Mix are for FY 2020 but
issuer is being updated for FY 2021)
- Retain the latest values available in the Fuel Mix and provide
Internal Notes on the Current Total Installed Capacity (MW),
Reported Percentage, Reported MW found in the latest company
report
Current Total Installed Capacity (MW)

• Definition: This data point evaluates the total capacity generated by the
company for the fiscal year.
Not applicable.
• Keyword(s):
capacity
- Please refer to Important Guidance on Current Total Installed
Capacity (MW), Reported Percentage, Reported MW, and
Renewables and Hydro Capacity (% of total capacity) for additional
important guidelines
- Only take the OWNED capacity into account.
- Please include capacity that is contracted TO another company for
operations, but not the capacity contracted FROM another
company
- Please do NOT include storage capacity here.
- Exclude pumped storage and battery capacity because that will
result in double counting.
- Scoring:
o Input the total installed capacity in MW.
Metrics used in reporting current renewable capacity

• Definition: This data point indicates the type of metric added in the
numerical fields for the data points to follow.
a) Percentage of total capacity (%)
b) Absolute capacity (MW)
c) N/A (e.g. transmission-only companies)
• Keyword(s):
Not applicable.
- Check Exposure tab for data available.
- Scoring:
o Percentage of total capacity (%) - Select this option if the
data available pertains to the percentage of capacity
generated from different renewable sources.
o Absolute capacity (MW) - Select this option if the data
available pertains to the capacity generated in megawatts.
o N/A (e.g. transmission-only companies) – Select this
option if a company does not have any generation capacity.
Reported Percentage
Capacity (MW), Reported Percentage, Reported MW, and Renewables
and Hydro Capacity (% of total capacity) for additional important
guidelines
- Ensure that the data placed are pertaining to the percentages of energy
capacity generated from different renewable sources
- If no value, do not place ‘0’ in text box unless specified in fuel mix.
Data Point Wind Solar Geothermal Biomass

percentage of wind percentage of solar percentage of percentage of
power capacity power capacity geothermal power biomass power
Definition
generated by the generated by the capacity generated capacity generated by
company company the company
Dropdown choices Numeric value Numeric value Numeric value Numeric value
Keyword(s) wind solar geothermal biomass
General Procedure Take value from Exposure > Fuel Mix.
Input the percentage Input the percentage Input the percentage Input the percentage
of wind capacity with of solar capacity with of geothermal of biomass capacity
respect to total respect to total capacity with respect with respect to total
installed capacity. installed capacity. to total installed installed capacity
capacity.
Data Point Waste Wave Tidal Hydro Wind

percentage of waste percentage of wave percentage of
energy capacity tidal power capacity hydropower capacity
Definition
generated by the generated by the generated by the
company company company
Dropdown choices Numeric value Numeric value Numeric value
Keyword(s) waste energy wave tidal hydro
General Procedure Take value from Exposure > Fuel Mix.
Input the percentage Input the percentage Input the percentage
of waste energy of wave tidal capacity of hydropower
General Procedure capacity with respect with respect to total capacity with respect
to total installed installed capacity. to total installed
capacity. capacity.
Reported MW
Capacity (MW), Reported Percentage, Reported MW, and Renewables
and Hydro Capacity (% of total capacity) for additional important
guidelines
- Place the energy capacity generated from different renewable sources
(absolute value)
- If no value, do not place ‘0’ in text box unless specified in fuel mix.
Data Point Wind Solar Geothermal Biomass

absolute wind power absolute solar power absolute geothermal absolute biomass
capacity generated by capacity generated by power capacity power capacity
Definition
the company the company generated by the generated by the
company company
Dropdown choices Numeric value N/A – Numeric value N/A – Numeric value N/A – Numeric value
Keyword(s) wind solar geothermal biomass
Take value from Exposure > Fuel Mix.
Input the absolute Input the absolute Input the absolute Input the absolute
General Procedure value of wind capacity value of solar value of geothermal value of biomass
in megawatts (MW). capacity in capacity in capacity in
megawatts (MW). megawatts (MW). megawatts (MW).
Data Point Waste Wave Tidal Hydro

absolute waste absolute wave tidal absolute hydropower
Definition energy capacity power capacity capacity generated by
the company
generated by the generated by the

company company
Dropdown choices N/A – Numeric value N/A – Numeric value N/A – Numeric value
Keyword(s) waste energy wave tidal hydro
Input the absolute Input the absolute Input the absolute
value of waste energy value of wave tidal value of hydropower
General Procedure
capacity in capacity in capacity in
megawatts (MW). megawatts (MW). megawatts (MW).
Renewables and Hydro Capacity (% of total capacity)

• Definition: This data point evaluates the company’s past trends in
renewable and hydro capacity.
Not applicable.
• Keyword(s):
human rights, security
Capacity (MW), Reported Percentage, Reported MW, and
Renewables and Hydro Capacity (% of total capacity) for additional
important guidelines
- Look up capacity for renewables and hydro since 2005.
- Scoring:
o Input percentage of renewable capacity + hydro capacity
with respect to total installed capacity per year.
• Calculation: [Renewable Capacity including Hydro
Capacity/Total Installed Capacity]*100
o Refer to the values available in Exposure > Fuel Mix to
calculate the percentage. Do not use other values.
o Do not add a row yet if there is no data available for that year
under Exposure > Fuel Mix
Practices – Programs & Initiatives

Green power option is offered to customers
• Definition: This data point evaluates whether the company offers purchase
of renewable energy or green certificates to customers.
a) Yes
b) No
c) Not Disclosed
• Keyword(s):
green power, customer, household

- Check whether the company offers the option to purchase
renewable energy or the option to purchase green certificates.
- If evidence is not immediately clear, check if the company has
renewable power purchasing agreements with specific companies.
- Score for direct electricity supply businesses. The company needs
to be in direct contact with end user (e.g., households, businesses)
- Score as ‘No value’ for pure play transmission & distribution
companies, power generators.
- Can be scored ‘No value’ in companies with distribution and supply
in Asia and Latin America.
- Scoring:
o Yes – Select this option if a company offers green power
options.
o No – Not used.
o Not Disclosed - No information found.
Commercialization of renewable power equipment

• Definition: This data point evaluates if the company offers renewable
energy equipment such as the installation of solar panels to customers or
waste-to-energy solutions.
a) Yes
b) No
c) Not Disclosed
• Keyword(s):
green equipment, solar panel
- Check whether the company offers renewable power solutions (e.g.
installation of solar panels, waste-to-energy solutions) at the
client’s location.
o Example: waste-to-energy solutions
- The issuer should bear the upfront capital cost for this data point
to be considered. Installations by third parties do not count.
- Do not be misled if the company provides education materials
regarding solar power. These do not count.
- Only applicable to RETAILERS AND SUPPLIERS or INTEGRATED
UTILITIES WITH LARGE SUPPLY SEGMENTS in US, Canada, Europe,
Australia or Japan.
- Score as ‘No value’ for all other companies.
- Scoring:
o Yes – Select this option if a company offers installation of
solar panels at the client’s location.
o No – Not used.
o Not Disclosed – Select this option if no information found
or if the issuer contracts/redirects the installation of solar
panels to a third party.
Practices – Strategy
Evidence of targets to increase renewable capacity
• Definition: This data point evaluates whether the company has targets to
increase renewable capacity.
a) Yes
b) No
c) Not disclosed
• Keyword(s):
target + capacity, target + solar, target + wind, etc.
- Score data point regardless of whether company currently has
renewable capacity.
- Only score if target is meaningful and tangible (e.g. 20-30% of new
capacity will be renewable energy). Vague statements or
meaningless targets (e.g. additional 100MW of renewable capacity
for a company with a total of 3000MW capacity) do not count.
- A company having planned capacity DOES NOT mean it has a
target.
- Only applicable to POWER GENERATORS or INTEGRATED
UTILITIES WITH MATERIAL POWER GENERATION BASE (i.e. >30-
40% revenue/operations come from power generation).
- Score as ‘No value’ for all other utilities (i.e. suppliers, retailers, or
transmission & distribution companies).
- Scoring:
o Yes – Select this option if meaningful and tangible target is
disclosed.
o No – Not used.
Internal structures to develop renewable capacity

• Definition: This data point evaluates whether the company has established
a structure to develop increased renewable capacity.
a) Dedicated renewable energy subsidiary or company is wholly involved in
renewables
b) Dedicated renewable energy department
c) Formalized renewable energy development program
d) No specific structure or plan to increase renewable capacity
• Keyword(s):
renewable capacity
- Disclosure can be found in the annual report, 10-K, CSR, or company
website.
- Only applicable to POWER GENERATORS or INTEGRATED
UTILITIES WITH MATERIAL POWER GENERATION BASE (i.e. >30-
40% revenue/operations come from power generation).
- Score as ‘No value’ for all other utilities.
- Scoring:
o Dedicated renewable energy subsidiary or company is
wholly involved in renewables – Select this option if a
company is wholly involved in renewable energy or has
subsidiary/ies dedicated to renewable energy.
o Dedicated renewable energy department – Select this
option if a company has a department dedicated to the
development of renewable capacity.
o Formalized renewable energy development program –
Select this option if the company has no specific
department but has a formal development plan to increase
renewable capacity.
o No specific structure or plan to increase renewable
capacity – Select this option if the company has no
renewable energy systems whatsoever.
Investments related to increased connection of renewable power to

electric grid
• Definition: This data point evaluates whether the company has made
investments related to increased connection of renewable power to
electric grid.
d) Yes
e) No
f) Not Disclosed
• Keyword(s):
investment + renewable, investment + grid, modernization, smart + grid,
voltage regulation + grid/network
- Disclosure can be forward-looking or pertain to the reporting year.
For some companies, investments for the year may be found in
annual reports, while others have CAPEX allotments for grid
modernization, smart meters, voltage regulation, which could
enable renewable energy connections to the grid.
- Only applicable to TRANSMISSION & DISTRIBUTION companies.
Score for both Lite and Full companies.
- Frequently checked for companies based in Asia and South
America.
- Score as ‘No value’ for suppliers and generators.
- Scoring:
o Yes – Select this option if investments related to increased
connection of renewable power to electric grid are
disclosed. DM default for T&D companies in Europe, US, and
Australia.
o No – Not used.
o Not Disclosed - No information found.
Total additional planned capacity (MW)

• Definition: This data point provides the company’s total additional planned
capacity in megawatts.
Not applicable.
• Keyword(s):
capacity
- Total additional planned capacity must:
o be owned by the company,
o be online within the next five years (or currently under
construction or development),
o have details on MW capacity, and
o have details on the projected fuel used.
- Be careful: this datapoint is often misconstrued as the company’s
target for renewable energy.
- Do not input total storage capacity here. This data point is for future
projects only.
- Scoring:
o Input the total additional planned capacity in MW. The value
of this data point must not be less than the total additional
planned capacity.
Additional renewable capacity (MW)

• Definition: This data point provides the company’s additional renewable
capacity in megawatts.
Not applicable.
• Keyword(s):
capacity
website.
- Additional renewable capacity must:
o be owned by the company,
o be online within the next five years (or currently under
construction or development),
o have details on MW capacity, and
o have details on the projected fuel used.
- Do not input total renewable capacity here. This data point is for
future projects only.
- Scoring:
o Input the additional renewable capacity in MW. The value of
this data point must not be greater than the total additional
planned capacity.
Renewable planned capacity as percentage of total planned capacity

• Definition: This data point provides a company’s renewable planned
capacity as a percentage of its total planned capacity.
Not applicable.
• Keyword(s):
capacity
website.
- Scoring:
o Input the percentage of renewable capacity with respect to
the total planned capacity as scored in the previous two
data points.
Packaging Material & Waste

This issue evaluates the extent to which companies may face lost market access or
compliance costs related to new regulations on product packaging and end-of-life
recycling or disposal. Scores are based on exposure to markets with evolving
packaging regulations; strategy and programs to reduce packaging waste;
demonstrated achievements; and controversies.
Additional Sources:
For progress and commitments: Signatory reports 2021 Global Commitment report
on plastic packaging (ellenmacarthurfoundation.org)
Practices
Strategy to reduce the environmental impact of packaging
• Definition: This data point refers to whether the company articulated a
strategy to reduce the environmental impact of its packaging.
a) Clear articulation of comprehensive strategy with significant details on
specific initiatives
b) Clear articulation of comprehensive strategy with limited details on
implementation
c) There is some evidence of targets or commitments
d) Specific programs or initiatives described but no clear comprehensive
approach
e) Evidence of some activities but no explicit targets or programs
f) No evidence
• Keyword(s):
Packaging, package, waste, paper, cardboard, glass, metal, plastic, pulp,
cullet, reuse, reusing, glass, metal, plastic, pulp, cullet, reuse, reusing, take-
back, take back, recycling, recycle, label, package design, lightweight,
lightweight, light weight, eco-friendly
- Scoring:
o Clear articulation of comprehensive strategy with
significant details on specific initiatives = the company has
a strategy on reducing the impact of their packaging in the
environment, supported with a detailed discussion on their
programs/efforts/initiatives
o Clear articulation of comprehensive strategy with limited
details on implementation = the company has a strategy on
reducing the impact of their packaging in the environment,
but discussion on their programs/efforts/initiatives is not

disclosed in further detail
o There is some evidence of targets or commitments = the
company commits to/has targets on reducing
environmental impact of their packaging but there are no
other supporting details mentioned
o Specific programs or initiatives described but no clear
comprehensive approach = the company only mentioned
specific programs/efforts/initiatives on reducing the
environmental impact of their packaging, but no supporting
details mentioned
o Evidence of some activities but no explicit targets or
programs = company generally mentioned some efforts on
reducing environmental impact of their packaging with no
supporting details mentioned
o No evidence = no disclosure
- Difference between options D and E:

o Select option E for companies with no disclosure on its
strategy and performance, only vague mentions of changes
in its products to make them more eco-friendly/more
sustainable. Example of a disclosure that merits an option
E credit:
• The packaging market is undergoing many changes.
First of all, the paradigm of packaging is
fundamentally changing as the social demand for
environment-friendly is increasing, which leads to
eco-friendly and simplified packaging. As individual
sub-distribution packaging increases, the proportion
of packaging and cardboard production units is also
increasing. Therefore, the packaging market is
changing with the motto of lightening and slimming,
and the products of our packaging business are also
spurring the advancement of manufacturing
facilities and the development of new high-value
products to cope with these changes." (YoulChon
Chemical Co., Ltd., 2020 AR pg 14)
o For option D, we usually select it for companies with very
limited disclosure on its strategy but has specific initiatives.
However, there's little information on its implementation (no
disclosure on specific plans/targets), and the
programs/initiatives usually just cover some products

within its portfolio. An example of a disclosure that merits
credit for this would be:
• Dongwon Systems
Expanding the Use of Green Products
- Producing lighter products
- Developing eco-friendly, low-carbon products
+
Yangban Seasoned Laver Eco-Friendly Package
removed previously-used the inside plastic
container used to protect the content from external
impact, which reduced the volume of the package
and total use of plastic film and paper used for the
product packaging. Yangban Seasoned Laver Eco-
Friendly Package is the first... It is developed based
on 2 years of research by Dongwon Systems, the
group’s total packaging materials company.
(Dongwon Group - Parent Company, 2020 CSR page
63)
• This is considered under Option D as the company

only has a general statement on product light-
weighting, and only disclosed progress/
achievements for one of its products, despite the
company's product portfolio (glass bottles, PET
bottles, aluminum cans, paper boxes, industrial
films, flexible plastic packaging, hygienic films,
aluminum foil).

Industry Guideline
- Sector: Consumer Staples
o “Comprehensive strategy” includes all the below
• Product light-weighting
• Use of recycled packaging content
• Use of renewable packaging materials (e.g., plant-
based)
• Efforts to takeback (or “recover”) post-consumer
packaging (i.e., used bottles) beyond those required
by law (i.e., the company has its own recovery
programs or partners with a local NGO rather than

“supporting” government initiatives)
• Efforts to educate consumers on recycling
- “Details on implementation” include details on:
o Scope of the programs (i.e., the % of packaging materials
that are part of the efforts, number of countries in which it
has recycling/recovery programs)
o Targets and evidence of progress
- Industry: Containers & Packaging

o Initiatives should be applied to most products and forward-
looking (initiatives will continue to improve and not just
allow the company's environmental footprint to be
stagnant) to get the top credit.
o For the waste recovery initiatives, this would be programs
such as take back initiatives or if the company is a signatory
of an organization that sponsors materials recovery
facilities (MRFs)
Disclosure of the overall packaging mix by type of material

• Definition: This data point refers to whether the company report its overall
packaging mix by type of material
a) Full disclosure
b) Partial disclosure
c) No evidence
• Keyword(s):
Packaging, package, waste, paper, cardboard, glass, metal, plastic, pulp
- Scoring:
o Full disclosure = the company disclosed ALL the
components/materials of their packaging (percentage
breakdown)
o Partial disclosure = the company only reports a list of
packaging materials used
o No evidence = no disclosure

Industry Guideline
- Sector: Consumer Staples

o We should look for the list of components/materials of their
packaging.
o Avoid giving credit if there is a mere mention that the
company is using cardboard. But the disclosure is not
comprehensive. Note that this should still be no evidence.

o List down the packaging materials that they are using
especially the sustainable ones.
• Full disclosure:
▪ If the list is comprehensive, use this option.
▪ Percentage of breakdown of the packaging
mix by type of material; quantitative
disclosure.
• Partial disclosure: the company only reports a list of
packaging materials used.
• No evidence = no disclosure found or vague
disclosure (e.g., Company is using recycled plastic.)
Scope of recycling programs in locations or circumstances where

packaging waste recycling is not mandated by law
• Definition: This data point refers to the company’s support on recycling
facilities in locations/or situations where waste recycling is not required by
law
a) Yes - as overarching strategy or policy
b) Anecdotal evidence in some locations
c) General statement
d) No evidence
• Keyword(s):
cullet, reuse, reusing, recycle, recycling
- Scoring:
o Yes – as overarching strategy or policy – if company will
explicitly make a policy on recycling program or if the
company has implemented recycling programs in majority

of the jurisdictions where they operate
o Anecdotal evidence in some locations – the company
discloses a few recycling programs in some markets
o General statement – the company aids governments to
support recycling programs but does not have its own
Industry Guideline
- Industry: Restaurants
o Instead of looking at recycling programs (given the
materials used in restaurants at large have low
recyclability), we instead assess whether the packaging
materials are designed to be environmentally friendly (i.e.,
using recycled fiber, biodegradable, compostable
substances)
Scope of consumers education programs on recycling (e.g. take-back

locations) and package design and labeling
• Definition: This data point refers to the company’s efforts on educating
consumers on recycling (e.g., take-back locations) and package design and
labeling
a) Yes - comprehensive programs in all locations
b) Anecdotal evidence in some locations or for some materials
c) General statement
d) No evidence
• Keyword(s):
cullet, reuse, reusing, take-back, take back, recycling, recycle, label,
package design, consumer education, educating consumer, customer
education, educating customer
- Packaging labels must indicate how used packaging can be
recycled by the consumer or where it can be dropped off for
recycling
- If the company has consumer awareness such as recycling logo,
region/industry specific notation on the packaging (e.g., instruction
or QR code providing the take-back/recycling locations where they
can drop the packaging/bottles).
- Scoring:
o Yes - comprehensive programs in all locations – the
company discloses the initiatives in all markets and all
operations
o Anecdotal evidence in some locations or for some
materials – the company discloses such initiatives in some
markets and some operations
o General statement – company mentioned that they educate
consumers/customers on recycling, package design and
labeling

Industry Guideline
o Yes - comprehensive programs in all locations:
• Check whether it covers all major operations and all
franchise location.
• Majority (i.e., around 90%) use this option. Provide
internal notes.
o If the company has franchises in different country, we need
to check whether they follow the same programs/practices
before we consider the highest score.
Scope of targets related to packaging content (e.g. lightweighted, recycled

content)
• Definition: This data point refers to the coverage of company’s
operations/locations where the target related to packaging content (e.g.,
light weighted, recycled content)
a) There is some evidence of targets or commitments
b) Targets have broad scope (company-wide or across all relevant
packaging)
c) Targets have narrow scope (apply to individual product or package lines
only)
d) No evidence
• Keyword(s):
cullet, reuse, reusing, recycling, recycle, lightweight, lightweight, light
weight, target, goal
- Examples of targets on packaging content are light-weighting, use
of recycled materials, reducing plastic content, use of eco-friendly
alternatives (plant-based packaging)
- Scoring:
o There is some evidence of targets or commitments –
company has targets or commitments on packaging
content but there are no sufficient details
o Targets have broad scope (company-wide or across all
relevant packaging) – company has targets on packaging
content that applies to all their operations or all their
packaging
o Targets have narrow scope (apply to individual product or
package lines only) – company has targets on packaging
content that applies to some of their operations or some of
their packaging
o No evidence – no disclosure/targets

Japan IMI
o Companies in Japan should normally have recycling
programs in place, since businesses such as food &
beverage companies, wholesale businesses, restaurants
operating takeaway services and packaging manufacturers
and importers are legally obliged to recycle packaging
waste.
o The Japanese government asks businesses to implement
recycling programs using one of the following ways:
• Voluntary recovery: companies themselves recover
packaging waste.
• Recovery program through the Japan Containers
and Packaging Recycling Association: Companies
pay fees to the Association. Then, the Association
implements recycling programs on behalf of the
company.
• Other: Companies pay other entities to implement
recycling programs.
o Despite this, Japan remains one of the largest generators of
plastic waste per capita, according to the UN. Please check
companies if are implementing measures to reduce the use
of plastic by light-weighting, using alternative materials or

any other innovative initiatives.
relevant packaging): We are looking at targets related to
improving packaging content. All innovations related light
weighting, increasing recycled content in its products and
other innovations are captured here. Check if the target
includes all major operations + franchises.
o If the company only disclosed about the operations, check
how many stores that the company owned and how many
are franchised. Check the franchise level to have more
understanding on company operations and its
practices/targets.
• If majority are franchised and the practice only
covers own operations, then choose ‘Targets have
narrow scope (apply to individual product or
package lines only)’
• If all their company-owned stores follow the same
practices and company-owned stores accounted for
90% of their operations, then choose ‘Targets have
broad scope (company-wide or across all relevant
packaging)’.

o This data point is product based. Check for the company’s
targets in terms of improving its packaging content. And
scoring depends on the extent of its portfolio that is covered
by the program.
o Quantitative targets that the company mentioned (e.g., the
company target in the next 5 years is to have bottles made
from recycled plastics for their XX products).
Future targets on packaging content (e.g. lightweighted, recycled content)

• Definition: This data point refers to the specific targets the company has
on packaging improving packaging content (e.g., light weighted, recycled
content)
a) Targets are specific and time-bound

b) Targets exist but are not time-bound or specific
c) No evidence
• Keyword(s):
- In terms of targets, make sure that the company mentioned a
baseline year, target year, and percentage reduction.
- Do not consider general statement about targets (i.e., the company
targets to have a XX percent of reduction in a specific product line
but there is no baseline and target year mentioned).
- Examples of targets on packaging content are light-weighting, use
- Scoring:
o Targets are specific and time-bound – the company’s
targets on packaging content are specific/detailed (target
value or percentage, etc.) along with a target year
o Targets exist but are not time-bound or specific –
company’s targets on packaging content do not have a
target year or specific/detailed (target value or percentage,
etc.)
o No evidence – no target/disclosure
Japan IMI
waste.
packaging waste.

company.
recycling programs.
- Industry: Restaurants and Consumer Staples

o If the company is aiming for 100% target, consider this as
evidence even if there is no baseline year.
o If the company’s target is not absolute 100% (e.g., 25% or
30% reduction) then, baseline year is needed.

o Targets exist but are not time-bound or specific – This
example can be considered for this industry.
• The company targets to have a XX percent of
reduction in a specific product line but there is no
baseline and target year mentioned.
Scope of product recovery targets

• Definition: This data point refers to the coverage of company’s
operations/locations where the target related product recovery applies to
a) There is some evidence of targets or commitments
b) Targets have broad scope (company-wide or across all relevant
packaging)
c) Targets have narrow scope (apply to individual product or package lines
only)
d. No evidence
• Keyword(s):
cullet, reuse, reusing, recycling, recycle, product recovery, recovery
program, target, goal
-
Efforts implemented by the company to recover used product
packaging; it should include their own packaging. Example of
targets: collection goals for each bottle sold/% of packaging
recovery among product sold
- Scoring:
o There is some evidence of targets or commitments –
company has targets or commitments on product recovery
but there are no sufficient details
relevant packaging) – company has targets on product
recovery that applies to all their operations or all their
packaging
o Targets have narrow scope (apply to individual product or
package lines only) – company has targets on product
recovery that applies to some of their operations or some of
their packaging
o No evidence – no disclosure/targets
Japan IMI
waste.
packaging waste.
company.
recycling programs.

Future targets on product recovery

• Definition: This data point refers to the specific targets the company has
on packaging improving product recovery
a) Targets are specific and time-bound
b) Targets exist but are not time-bound or specific
c) No evidence
• Keyword(s):
program, target, goal
- Scoring:
o Targets are specific and time-bound – the company’s
targets on product recovery are specific/detailed (target
value or percentage, etc.) along with a target year
o Targets exist but are not time-bound or specific –
company’s targets on product recovery do not have a target
year or specific/detailed (target value or percentage, etc.)
o No evidence – no target/disclosure
Japan IMI
waste.
packaging waste.
company.

recycling programs.
o Not relevant to the industry use these options instead as
corresponding options from the dropdown. Check whether
there is evidence of facilitating end-of-life product collection
from customers?
• Targets are specific and time-bound: Offers take-
back programs for end-of-life products at store or
designated pick-up locations
• Targets exist but are not time-bound or specific:
Discloses having a recycling program, without any
further evidence
Performance
Achievements on packaging content (e.g. light-weighted, recycled
content) Commented [LRA76]: Pending query with Content
• Definition: This data point refers to the company’s achievements on their Team. Below query is available in Adhoc Teams
Channel.
target on packaging content (e.g., light-weighted, recycled content)
• Dropdown choices: May we ask guidance on options b-d?
a) Achievements have broad scope (company-wide or across all relevant
packaging)
b) There is evidence of improvement
c) Achievements apply to individual product or package lines only
d) General statement
e) No evidence
• Keyword(s):
-
Examples of targets on packaging content are light-weighting, use
Japan IMI
waste.
packaging waste.
company.
recycling programs.
Achievements on product recovery

• Definition: This data point refers to the company’s achievements on their
target on product recovery
a) Achievements have broad scope (company-wide or across all relevant
packaging)
b) There is evidence of improvement
c) Achievements apply to individual product or package lines only
d) General statement
e) No evidence
• Keyword(s):
program, target, goal, MRF, material recovery facility
- Efforts implemented by the company to recover used product
packaging; it should include their own packaging. Example of
targets: collection goals for each bottle sold/% of packaging
recovery among product sold
- What if the company has achievements for all packaging but only
for specific company locations?
o Check for the percentage of revenue coming from the
specific location. Since it is possible that the company
might be deriving only 10% revenues from that location. In
that case, it is inappropriate to give the highest scoring.
Japan IMI
waste.
packaging waste.
company.
recycling programs.

o Not relevant to the industry use these options instead as
corresponding options from the dropdown. Check whether
there is evidence of engagement initiatives with customers
on advancing circular economy efforts?
• Achievements have broad scope (company-wide or
across all relevant packaging): Supporting deposit-
return scheme development
• There is evidence of improvement: Improving
recycling/reusable labelling of its packaging
materials
• Achievements apply to individual product or
package lines only: Evidence of providing
Incentives for take-back program for end-of-life
products (credit against new purchases, lease vs
Buy etc.)
• General statement: Evidence of consumer
awareness programs to encourage responsible
consumption

o If the company sponsors Material Recovery Facility (MRF)
projects, score ‘Achievements have broad scope (company-
wide or across all relevant packaging)
Privacy & Data Security

This issue evaluates the extent to which companies may face regulatory risks, cost
increases or reputational damage from a data breach or controversial use of
personal data. Scores are based on involvement in handling sensitive personal data
and exposure to evolving regulations; strength of policies and practices to control
data collection and usage, strength of data security management systems; and
involvement in data breaches and controversies.
Performance – Products & Services

Commercialization of Services and Products that Contribute to Cyber
Resilience
• Definition: This data point refers to commercialization of services and
products that contribute to cyber resilience, leading to revenue generation
of the company.
(a) Pure-Play (>50% of revenues)
(b) Core Business (20-50% of revenues)
(c) Non-core Involvement (<20% of revenues)
(d) R&D underway or exploring opportunities
(e) No evidence
• Keyword(s):
Cyber security, cybersecurity, cyber-security, cyber resilience, cyber-
resilience, cloud security, managed security services (MSS)
- Growing interest from an investment opportunity perspective on the
subject to identify companies that are well positioned to tap growing
demand for information security services & products. The global
cybersecurity resilience or solutions market is expected to grow from
USD 63.7bn in 2011 to USD 120.1bn by 2017, making it one of the
fastest growing IT sub-sectors with an estimated CAGR of 11.3% from
2012 to 2017 (Source: MarketsandMarkets).
- Relevant for the Software and Services industry and Communications
Services issuers, particularly for Telecom services providers (typically
offered as B2B/enterprise products)
- Identify whether the company provides products or services to
customers/consumers on cyber resilience.
- Scoring:
o Pure play (revenues >50%): company's revenues mostly
come from the products or services offered (company is the
leading player in the given market)
Core Business (revenues 20-50%): Products or services in

o
this area constitute at least half of revenues (you may not
be able to get exact figures, but make your best estimate)
or the company is a major player in each market
o Non-core business (revenues <20%): relatively minor
component manufacturing, products or services in this area
constitute less than 20% of revenues (make your best
estimate), or the business segment is marginal to the
company
o R&D underway /exploring opportunities: a company is
engaged in R&D in this area and/or has one or more
offerings but they represent a negligible portion of revenues
o No evidence: there is no evidence/disclosure
Industry Guidelines
- Industry / Sub-Industry: Food & Staples Retailing (i.e., SI: Drug Retail,
Food Distributor, Food Retail, Hypermarkets & Super Centers)
- Guideline: This should be no value unless issuers disclosed about
selling antivirus/data protection software or providing services related
to cyber resilience which is very rare.
- Industry / Sub-Industry: most Retail - Consumer Discretionary

companies
- Guideline: No value for most Retail - Consumer Discretionary companies
unless they are explicitly involved in commercializing products (e.g.,
Amazon). Like Food Retail.
- Industry / Sub-Industry: Financials sector

- Guideline: leave at No Value
Type of products (e.g. encryption, cryptographic software, anti-virus,

cloud security)
• Definition: This data point refers to types of products that contribute to
cyber resilience.
N/A - Long text
• Keyword(s):
Cyber security, cybersecurity, cyber-security, cyber resilience, cyber-
resilience, cloud security, managed security services (MSS)
- Scoring: Add details about the products provided by the company on

cyber resilience
Performance - Privacy and Data Security Metrics - Data

Breaches
Number of Data Breach Instances
• Definition: This data point refers to the number of data breach instances
• Keyword(s):
Breach, complaint, incident
- Scoring: Place in the number of data breaches the company has
experienced throughout the year
Number of Data Incident / Customer Complaints

• Definition: This data point refers to the total number of data
incident/customer complaints
• Keyword(s):
- Scoring: Place in the number of customer complaints or data incidents
the company has experienced throughout the year
Records Lost
• Definition: This data point refers to the total number of records lost during
the breach.
• Keyword(s):
- Scoring: Place in the number of records lost by the company has during
the breach/breaches throughout the year
Attack Vector
• Definition: This data point refers to the attack vector used to obtain system
access/network. An attack vector is a method or way an attacker can gain
unauthorized access to a network or computer system (Source: UpGuard,
Inc.). Examples are compromised credentials, Weak credentials, Malicious
insiders, Missing or poor encryption, Misconfiguration, Ransomware,
Phishing, Vulnerabilities, Brute force, Distributed Denial of Service (DDoS),
SQL injections, Trojans, Cross-site scripting (XSS), etc.
N/A - Long text
• Keyword(s):
- Scoring: Place in the mode/s of breach/infiltration of the attacker in
the company’s systems throughout the year
Details (e.g. liability or legal action, cost of data breach)

• Definition: This data point refers to additional details on the breach.
N/A – free text
• Keyword(s):
- Scoring: Place in the details of the breach; costs of data breach, when
the breach took place, legal action taken, measures done to address
the breach, etc.
Performance - Privacy and Data Security Metrics - Data Security

Investments
Investment in Data Security (in USD mn)
• Definition: This data point refers to the total amount of company's
investment related to data security expressed in million USD.
• Keyword(s):
Data security investment, data security
- Scoring: Place in the amount invested by the company on Data Security
Total Assets (in USD mn)

• Definition: This data point refers to the total assets of the company
expressed in million USD.
• Keyword(s):
Assets
- Scoring: Place in the amount invested by the company on Data Security
o Source Total Assets (in USD million) from Exposure tab or
from the company’s annual reports.
Details (e.g. type of investments, technology adopted, etc.)

• Definition: This data point refers to additional details on the type of
investment the company has on data security.
N/A – free text
• Keyword(s):
Data security investment, data security
- Scoring: Please put details on the investment made by the company on
data security (e.g., type of investments, technology adopted on specific
encryption and authentication protocols or techniques, etc.)
Additional Exposure Indicators - Impact

Company collects information about its customers or other individuals
• Definition: This data point provides information if the company collects
information about its customers or other individuals.
(a) Yes
(b) No
• Keyword(s):
Personal data, personal information, customer data, customer information
- Scoring:
o Yes – default (for most companies using this KI)
o No – If the company is an outlier in the industry and
indicates that it does not collect data EVEN ON VISITORS
TO ITS WEBSITE. This is extremely RARE (Sample privacy
policy states: "We do not collect any information on visitors
who browse our web site. Cookies are not installed onto
your computer.")
Industry Guidelines
- Market: Developed Market
Scope of company’s publicly available data protection policy
• Definition: This data point refers to the scope of company’s publicly
available data protection policy.
(a) Policy governs all relevant business lines/subsidiaries
(b) Policy governs selected business lines/subsidiaries
(c) Policy applies to corporate website only
(e) No evidence
• Keyword(s):
Public, data policy, privacy policy, data protection, cyber security, cyber-
security, cybersecurity, data security
- If the company has multiple privacy policies, analyst should investigate
all of them.
o If there are different scopes per policy, check which policy
applies overall
- We are identifying here whether there are some rules in place/basic
information provided to stakeholders about data collection and
handling practices across the company’s relevant operations. A vague
statement referring to privacy is not enough to be considered as a
privacy policy. We should only consider data protection policy which
contains at least the following basic provisions:
o Clarifying collection purposes
o Clarifying means by which the company collects data
o Clarifying whether third parties have access to data and for
what purposes.
• Example: company enumerates the kind of
data/item received or shared with a particular third
party
- For EU GDPR and California privacy policy provisions, if there are
indications that each location has their own privacy policies, the main
policy might not be overarching since there are different standards per
location based on specific policies (only selected business lines).
- Watch out for privacy policies that seem comprehensive but only apply
to the company’s website. For certain web companies, this will in fact
represent the majority or entirety of their business, but for most
companies it will not.
- Scoring:
o Policy governs all relevant business lines/subsidiaries –
the company’s privacy policy applies all of their operations
o Policy governs selected business lines/subsidiaries – the
company’s privacy policy applies to some of their
operations
o Policy applies to corporate website only – the company’s
privacy policy is only for their website
norms – currently not being used; please do not use this
score
JP IMI
o Most companies would have a privacy policy disclosed on
their website. It can be often found at the very bottom of the
website.
o Keywords in Japanese: “プライバシーポリシー”, “個人情報
保護方針”, “個人情報の取扱い”
Rights provided to individuals regarding the control of their data

• Definition: This data point refers to the rights individuals have regarding
the data they share to the company. As consumers’ awareness and
concerns around privacy rights grow, digital rights are likely to develop (i.e.,
rights to be forgotten). In addition to benefiting to consumer trust, this also
positively contributes to accuracy and minimization of data handled by
companies.
(a) Right of access, rectification and deletion of individuals' data
(b) Right of deletion of individuals' data
(c) Right of access and rectification of individuals' data
(e) No evidence
• Keyword(s):
Rectify, rectification, modify, update, remove, delete, access, erase, erasure
- Look for basic digital rights given to individuals to control information
collected on them.
- Rights of deletion: Allowing customers or users to delete all data on
them / company should not be able to retrieve data (i.e., data becomes
cyber-attacks free)
o Common terminologies: Right to erasure or right to be
forgotten
- Scoring:
o Right of access, rectification and deletion of individuals'
data – the customer can request to access, rectify/correct,
AND delete the data they have provided to the company;
additional information must be disclosed by the company
(there must be more information on the conditions that
must be fulfilled to access, rectify, and delete data)
o Right of deletion of individuals' data
• Choose this option if the disclosure contains the
following information:
▪ The user can make a request to delete ALL
of their personally identifiable data (PII).
▪ The company will honor the request and
provide a timeframe (i.e., how many days/
weeks/ months will they take before the
deletion happens).
▪ It is clear from the disclosures that post
deletion the data is ‘irretrievable’ (i.e., the
company cannot access it at all, not even
through 3rd parties).
• Disclosure should complete the loop – request >
timeline of deletion > complete non-access.
• For Financial companies – which are prudentially
regulated entities
▪ Right to deletion is contingent to applicable
law of data retention. Even if the user has the
right to deletion, the regulations mandate
data retention for a certain period. Hence, we
cannot choose ‘Right of deletion of
individuals' data’
This needs to be evaluated for all Financial

▪
Sector companies.
o Right of access and rectification of individuals' data – the
customer/consumer can request to access and
rectify/correct the data they have provided to the company.
score.
o No evidence – no information found

Industry Guidelines
- Market: Retail - Consumer Discretionary Industry and
Communications Services sector
- Default Scoring: we do not give credit for digital rights only
applicable in specific locations such as Rights for California
residents. However, while the current practice is not to consider
specific jurisdiction rights (e.g. California Consumer Privacy Act
(CCPA) or Nevada), there is ongoing internal consultation if an
alternate approach should be considered.
Data Breach/ Incident Response Plan

• Definition: This data point provides information on measures of the
company to address data breaches or if the company has an incident
response plan. No companies or organizations are safe from data breach
or incident so preparedness to this risk is paramount to reduce the chances
of getting attacked, the gravity and longevity of the attack and the incurred
cost of the attack.
(a) Both proactive and reactive measures are in place
(b) Proactive measures are in place
(c) Reactive measures are in place
(d) General statements on data breach/ incident response plan
(f) No evidence
• Keyword(s):
Breach, incident, response, prevent, minimize, protect, data, vulnerability
assessment, risk assessment, back-up, back up, intrusion, response team,
vulnerability testing
- Encryption is neither proactive nor reactive (general)
- Proactive: programs/measures that take effect prior breach and can

reduce the risk of breach happening. Examples include (but are not
limited to): vulnerability assessment, monitoring network in real-time
(as a means of detecting suspicious use), penetration testing (can be
done by an external/third party), incident team in place, detailed
incident plan, data mapping & back-ups, threat detection or intelligence,
firewalls
o For penetration testing, do not confuse with the statement
“external audits”
- Reactive: programs/measures that take effect post breach and can
reduce cost of data breach and risk of reoccurring. Examples include
(but are not limited to): identity theft/cyber security insurance,
investigations are conducted (e.g., incident management reporting
channels and recovery mechanisms), remediation measures,
notification plan, disaster recovery plans (only for data
breaches/incidents)
- Scoring:
o Both proactive and reactive measures are in place –
company has both proactive and reactive measures to
reduce the possibility/incidences of breach
o Proactive measures are in place – the company has
proactive measures to minimize a data breach from
occurring
o Reactive measures are in place – the company has
systems in place to respond a data breach and to prevent
another breach from occurring
o General statements on data breach/ incident response plan
– the company refers to a data breach/incident plan but
does not provide further details on what it encompasses.
use this score if the company states encryption only
norms – currently not being used; please refrain from using
o No evidence – no information found
Information Security Policies and Systems audit frequency

• Definition: This data point provides information on the company's audit
frequency on their information security policies and systems.
(a) External independent audits are conducted at least once every two
years
(b) Internal audits are conducted at least once every two years
(c) General statements on conducting information security audits

(e) No evidence
• Keyword(s):
Audit, Security audit, Information audit, certification, ISO 27001, ISO-27001,
ISO27001, TRUSTe, JIS Q 15001, JIS Q15001, Privacy Mark, SSAE 16 SOC
2, PCI DSS
- Common certifications are ISO 27001, TRUSTe, JIS Q 15001, Privacy
Mark
- PCI DSS certification is usually found on payment processing
companies, Retail industries, and gaming companies from
Communications Services sector (M&E)
- Please note certifications have expiration date, so please check the
most recent status, rather than taking certification from years ago as
granted (Example: ISO27001 is only valid for three years). Therefore,
we should only give the highest credit (external independent audit) if
there’s evidence of company maintaining/renewing its certification
- Do not give a score if the company only aligns, follows, adheres to the
standards of a certification. It must be stated by the company that they
are certified to the certification mentioned
o For issuers with TRUSTe certification
• Do not give a mark for general statements on TRUSTe
certification. Only consider CLEAR and EXPLICIT
certifications. Check what the TRUSTe certification
covers; it may not be all operations or even all
websites. Do not give credit if the certification
covers only a superficial amount of
operations/products/subsidiaries. See below link
• https://compliance.salesforce.com/en/truste-
privacy-verified-seal
- Scoring:
o External independent audits are conducted at least once
every two years – If there is evidence of external
certification which implies independent audit for major
relevant business lines/operations either annually or every
two years; give credit if issuer is certified to TRUSTe but
check the scope of the certification as it may not be all
operations or even all websites. Do not give credit if the
certification covers only a superficial amount of
operations/products/subsidiaries.
You can search for your company here:

https://www.truste.com/consumer-resources/trusted-
directory/
o Internal audits are conducted at least once every two years
– if there is evidence of internal audits for major relevant
business lines/operations either annually or every two
years; give credit for Japanese issuers if they have
certifications on Privacy Mark and/or JIS Q 15001.
o General statements on conducting information security
audits – if there is evidence of security audits but there are
no details on scope and frequency of audits.
score
Industry Guidelines
- Industry/Sector: Software & Services
- Guidance:
o Privacy Mark certification – if there are no additional
information on the certification, Internal Audit should
receive the maximum credit
o TRUSTe certification – consider TRUSTe Privacy Verified
Privacy Seal.
• In the absence of further information, give credit for
Internal Audits
• For additional information on assessment services
and external audits, use External Audits credit
- Industry/Sector: Retail – Consumer Discretionary Industry
- Certification Guidance: For PCI DSS certification,
- Scoring: give lowest credit (General statement) for audits
- Certification Guidance: For TRUSTe certifications
- Scoring: give credit for External independent audits are conducted at
least once every two years
o You can also search for your company here:
directory/
- Certification Guidance: For issuers with ISO 27001 or JIS Q27001
(Japan)
- Scoring: Give minimal credit of Internal audits are conducted at least
once every two years if no other evidence found
Company's executive body responsible for: Privacy and Data security

• Definition: This data point provides information on the governing body
responsible for Privacy and Data security in the company.
(c) Corporate Social Responsibility/ Sustainability team
(d) Special task force or risk officer
(f) No evidence
• Keyword(s):
Officer, Chief Technology Officer, Chief Information Security Officer, Chief
Privacy Officer, Chief Data Security Officer, Data Security Risk Officer,
committee, Data protection officer, Privacy officer, ISO 27001, JIS Q27001,
TRUSTe
given when there is clear evidence of their involvement in managing
Privacy & Data Security (Cyber security) or being directly responsible
for Privacy & Data Security related issues/practices/performance of
the company (not just based on a mere mention of board members or
executive officers).
- For contractors hired for this purpose, use judgement to determine
whether the position/officer/team/committee falls under Corporate
Social Responsibility/ Sustainability team or Special task force or risk
officer score
- Scoring:
o Board-level committee – score if the responsibility on
Privacy and Data Security falls on the Board of Directors, or
Board Committees
o C-suite or Executive committee – score if the responsibility
on Privacy and Data Security falls on a c-suite or executive
officer/committee. Examples include (but are not limited
to): Chief Information Security Officer and/or Chief Privacy
Officer who is part of the executive
management/committee
o Corporate Social Responsibility/ Sustainability team –
score if the responsibility on Privacy and Data Security falls
in the company’s CSR/SR team or committee. Ensure that
Privacy & Data Security is also included in their CSR/SR/ESG

scope
o Special task force or risk officer – score if the responsibility
on Privacy and Data Security falls in the company’s risk
officer or a dedicated special task force/team; general
mentions of officers/c-suites but do not have clear evidence
that they are part of the executive management/committee
norms – currently not being used; please refrain from using
this score
Industry Guidelines
- Guidance below are on certifications. Please note certifications
have expiration date, so please check the most recent status, rather
than taking certification from years ago as granted. Credits are only
given if there’s evidence of company maintaining/renewing its
certification. Additionally, do not consider if the company only
aligns, follows, adheres to the standards of a certification. It must
be explicitly stated by the company that they are certified to the
certification mentioned
- Industry/Sector: Software & Services
- Certification Guidance: For issuers with TRUSTe certification
- Scoring: Do not give a mark for general statements on TRUSTe
certification. Only consider CLEAR and EXPLICIT certifications.
o Check what the TRUSTe certification covers; it may not be
all operations or even all websites. Do not give credit if the
operations/products/subsidiaries.
o See link https://compliance.salesforce.com/en/truste-
• In the absence of additional information, give
minimum credit for Special task force or risk office
• In the presence of clear and explicit information on
PDS responsibility, higher score may be used
depending on the appropriate score based on the
disclosure
- Industry/Sector: Retail – Consumer Discretionary
(Japan)
- Scoring: Give minimal credit of Special task force or risk officer if

no other evidence found
o Higher score may be used depending on the appropriate
score based on the disclosure
Evidence of access control and protection of personal/sensitive data

• Definition: This data point provides information if there is an evidence of
access control and protection of personal/sensitive data.
(a) Access control and encryption/de-identification techniques are in place
(b) Encryption/de-identification techniques are in place
(c) Access control techniques are in place
(d) No evidence
• Keyword(s):
Protection, encryption, de-identification, de identification, least privilege
user access, LUA, Identify access management system, IAM, 2FA, two-
factor authentication, multi-factor authentication, MFA, Secure Sockets
Layer (SSL), TRUSTe
- Encryption/De-identification: e.g., encryption of sensitive/personal
data, encrypt web traffic (through SSL/TLS); endpoint encryption
(endpoint devices: computing devices that remotely access to
corporate network such as Point-of-Sales terminals or connected
devices); end-to-end encryption. Encryption means your sensitive data
is useless to criminals or unauthorized viewers. De-identification or
anonymization (i.e., removal of personally identifying information) of
data-sensitive information such as healthcare records or financial
information. Data becomes privacy-risk-free; even if stolen or lost, they
can't be associated with a certain individual.
- For issuers with TRUSTe certification
o Please note certifications have an expiration date, so please
check the most recent status, rather than taking
certifications from years ago as granted. Credits are only
given if there’s evidence of a company
maintaining/renewing its certification. Additionally, do not
consider if the company only aligns, follows, and adheres to
the standards of a certification. It must be explicitly stated
by the company that they are certified to the certification
mentioned.
o Do not give a mark for general statements on TRUSTe
certifications. Check what the TRUSTe certification covers;

it may not be all operations or even all websites. Do not give
credit if the certification covers only a superficial amount of
operations/products/subsidiaries. See below link:
https://compliance.salesforce.com/en/truste-privacy-
verified-seal
- Scoring:
o Access control and encryption/de-identification
techniques are in place – score if the company has access
control and encryption/de-identification
techniques/systems in place; if the company is TRUSTe
certified, give this score
o Encryption/de-identification techniques are in place –
score if the company only has encryption/de-identification
techniques/systems in place
o Access control techniques are in place
• score if the company only has access control
techniques/systems in place.
• For Financials:
▪ Do not consider a mere mention or general
statement about access control techniques.
▪ The company should at least explicitly
disclose their access control techniques in
place or their second level of security.
Access control includes the following, but is
not limited to
▪ two/multi-factor authentication for
privileged users and/or for remote
access,
▪ biometric authentication
▪ least privilege user access (LUA),
▪ Identity Access Management system
(IAM)
▪ limit access to personal/sensitive
data to designated personnel on a
'need to know' basis.
JP IMI
Though it is not mandated by law, businesses are

o
encouraged to adopt encryption mechanisms for data
protection. Please check if the company has such measures
in place.
• CRYPTREC Ciphers List:
https://www.cryptrec.go.jp/list.html
Industry Guidelines
- Certification Guidance: If issuer has TRUSTe certification
- Scoring: Access control and encryption/de-identification techniques
are in place
directory/
Practices and consent requirements around handling of personal data by

third parties
• Definition: This data point provides information if there are practices and
consent requirements around handling of personal data by third parties.
Data analytics/big data developments have given rise to targeted
marketing, offering, and pricing services based on analysis of consumers’
purchasing habits. These practices, notably when denying explicit and
active consent to data subjects, have crystalized mounting public
concerns. Companies involved in these practices could be vulnerable to
regulatory pressure and consumer backlash.
(a) Company does not rent, sell, or provide personal data to third parties for
purposes other than completing transactions/services
(b) Opt-in for providing personal data to third parties for purposes other
than completing transactions/services
(c) Opt-out for providing personal data to third parties for purposes other
than completing transactions/services
(d) No evidence
• Keyword(s):
Sell/rent, rent/sell, consent, sensitive data, sell or rent, rent or sell, opt-in,
opt-out, opt in, opt out
- This is usually found on company websites under their privacy policy
webpage.
- Look for the commitment not to share personal data with third parties
for purposes that do not benefit the individual user or customer (e.g.,
selling or providing your transaction history/purchasing habits to other
merchants). Being advertised to, does not count as a benefit for the
user/customer. If it does this type of sharing, then we are looking at
whether opt-in or opt-out are offered to customers.
- Many companies will share data with external parties for the purpose
of completing transactions/contract (e.g., if you use your Visa card to
purchase something, Visa must share certain data with the merchant
to complete the purchase) or for processing or analysis on behalf of
the company itself. These types of sharing are OK.
- If personal data is anonymized or aggregated (summarized), it is OK.
- Places where the company says it won’t sell/rent/share/etc. personal
information except as permitted by law. This offers very little
assurance and should not get be given a score.
- Scoring:
o Company does not rent, sell, or provide personal data to
third parties for purposes other than completing
transactions/services – the company states that they do
not give out personal data by any means to any third parties
other than necessary purposes for transaction completion
or services.
o Opt-in for providing personal data to third parties for
• if the company states they opt-in/choose to share
personal data to third parties other than necessary
purposes on transactions/services.
• For Financials: Do not consider any marketing-
related disclosure here.
o Opt-out for providing personal data to third parties for
• if the company states they opt-out/choose not to
share personal data to third parties other than
necessary purposes on transactions/services.
• For Financials: Do not consider any marketing-
related disclosure here. Focus on restricting/
withdrawing consent for "personal data" rather than
"marketing information.
▪ Example NOT to be considered: You may tell
us at any time that you do not wish to receive
any further marketing materials by sending
an email to XXX and we will stop sending you

such materials unless you consent to
receiving them again.
▪ Example to be considered: If the customer
has consented to the use of personal data,
the consent can be withdrawn at any time.
The consents are managed on MinSide.
o No evidence – no disclosure or if the company says it won’t
sell/rent/share/etc. personal information except as
permitted by law (this offers very little assurance and should
not get be given a score).
Minimizes data collection and retention

• Definition: This data point provides information company minimizes data
collection and retention. It also identifies whether the company
participates to the principle of minimizing amount of data handled on
customers/individuals. This captures another risk of data misuse through
combinations of consumers’ information from multiple sources (which can
then be plugged into differing score algorithms and models).
(a) The company commits to deleting data after a defined amount of time
and does not collect personal data from third parties (except when required
by law)
(b) The company commits to deleting data after a defined amount of time
(c) The company does not collect personal data from third parties (except
when required by law)
(d) No evidence
• Keyword(s):
Retention, period, duration, delete, erase, erasure, retain
- This is usually found in company websites under their privacy policy
webpage
- Deleting data after a defined amount of time/specific time frame (e.g.
days, months, years).
o Sample statement of this is: “we keep search histories for
six months and then delete”.
- Examples of these are: “the company only retains your data as long as
allowed/required by law,” or “as long as there is a business need” DOES
NOT COUNT and should not get credit.
- Deletion of data should cover all or majority (covers core operations)

of the data collected by the company. If the data deletion is only for
few/some data, do not give credit
- Scoring:
o The company commits to deleting data after a defined
amount of time and does not collect personal data from
third parties (except when required by law) – score if the
company states that they delete
customer/consumer/individual data after a defined amount
of time/specific time frame AND they do not collect
personal data from third parties
o The company commits to deleting data after a defined
amount of time – score if the company states that they
delete customer/consumer/individual data after a defined
amount of time/specific time frame
o The company does not collect personal data from third
parties (except when required by law) – score if the
company states that they do not collect personal data from
third parties
o No evidence – no disclosure or if the company states
something like “the company only retains your data as long
as allowed/required by law,” or “as long as there is a
business need” (does not count as a valid disclosure)
Industry Guidelines
- Certification Guidance: TRUSTe
o Experience shows not all TRUSTe certified companies
explicitly give this information in the privacy policy.
- Scoring: do NOT give credit for commitment to delete data after a
certain amount of time unless company has sated EXPLICITLY
Practices - Employees
Scope of employee training on data security and/or privacy-related risks
& procedures
• Definition: This data point provides information on the scope of employee
training on data security and/or privacy-related risks & procedures.
Training is crucial to educate employees/contractors who are often the
targets of cyber-attacks and prevent insider errors/attacks (often more
difficult to identify). A significant proportion of breach incidents results
from accidental loss and malicious insider (40% of 2014 data breach
recorded by the Breach Level Index, Sources: Gemalto & SafeNet).
(a) Training is provided to all employees, including contractors
(b) Training is provided to all permanent employees
(c) Training is provided to selected employees or scope unclear
(e) No evidence
• Keyword(s):
Training, privacy training, data protection training, security training, ISO
27001, ISO-27001, ISO27001, TRUSTe, JIS Q 15001, JIS Q15001, SSAE 16
SOC 2, SOC2, Privacy Mark, cybersecurity awareness, cyber awareness
training, cyber awareness, cybersecurity
- For issuers with TRUSTe certification
o Please note certifications have expiration date, so please
check the most recent status, rather than taking
certification from years ago as granted. Credits are only
given if there’s evidence of company maintaining/renewing
its certification. Additionally, do not consider if the company
only aligns, follows, adheres to the standards of a
certification. It must be explicitly stated by the company that
they are certified to the certification mentioned
operations/products/subsidiaries
(https://compliance.salesforce.com/en/truste-privacy-
verified-seal)
- Scoring:
o Training is provided to all employees, including
contractors – if company has evidence of training to all
employees, including contractors. Do not choose this score
unless there is clear evidence that the company trains all
employees and contractors comprehensively
o Training is provided to all permanent employees – if
company has evidence of training to all permanent
employees or if they stated that they train all employees (but
no specific details on whether they are permanent,

temporary, or contractual
o Training is provided to selected employees or scope
unclear – If the company has evidence of training but no
indication of scope; if a company has TRUSTe certification,
ISO 27001 certification, Privacy Mark, and/or JIS Q 15001
(the latter 2 certifications are for Japanese issuers), use this
score if no evidence on the scope of training is provided
score
Industry Guidelines
- Industry/Sector: Software & Services and Retail – Consumer
Discretionary industry
- Certification Guidance: For issuers with TRUSTe certification –
consider TRUSTe Privacy Verified Privacy Seal.
o In the absence of additional information, give minimum
credit for Training is provided to selected employees or
scope unclear
o In the presence of a clear and explicit disclosure on training
being conducted for all employees or all employees
including contractors, higher score may be used depending
on the appropriate score based on the disclosure
o For Retail – Consumer Discretionary ONLY: You can also
search for your company here:
directory/
- Industry/Sector: Retail – Consumer Discretionary
(Japan)
o Give minimal credit of Special task force or risk officer if no
other evidence found
• In the presence of a clear and explicit disclosure on
training being conducted for all employees or all
employees including contractors, higher score may
be used depending on the appropriate score based
on the disclosure
o Do not consider if the company only aligns, follows, adheres

to the standards of a certification. It must be explicitly
stated by the company that they are certified to the
certification mentioned
Practices - Certification
Scope of certification to widely recognized standards (e.g. ISO 27001,
TRUSTe, Privacy Mark, SSAE16 soc2 standards)
• Definition: This data point provides information on the scope of
certification to widely recognized standards (e.g. ISO 27001, TRUSTe,
Privacy Mark, SSAE16 soc2 standards). While these certifications ensure a
certain level of data security profile, they are also becoming key advantage
or requirement in tender process with business customers.
(a) Most (over 80%) owned operations are certified to widely accepted
standards
(b) Some (over 20% and below 80%) owned operations are certified to
widely accepted standards
(c) Few (less than 20%) owned operations are certified to widely accepted
standards
(d) Evidence of certification but scope not defined
(e) Company intends to pursue widely accepted certification
(f) No evidence
• Keyword(s):
ISO 27001, ISO-27001, ISO27001, TRUSTe, JIS Q 15001, JIS Q15001, SSAE
16 SOC 2, SOC2, Privacy Mark
- Common certifications are ISO 27001, TRUSTe, JIS Q 15001, SSAE 16
SOC 2, Privacy Mark
most recent status, rather than taking certification from years ago
as granted (Example: ISO27001 is only valid for three years).
Therefore, we should only give the highest credit (external
independent audit) if there’s evidence of company
maintaining/renewing its certification
- Do not give a score if the company only aligns, follows, adheres to
the standards of a certification. It must be explicitly stated by the
company that they are certified to the certification mentioned
• Do not give a mark for general statements on

TRUSTe certification. Only consider CLEAR and
EXPLICIT certifications. Check what the TRUSTe
certification covers; it may not be all operations or
even all websites. Do not give credit if the
▪ https://compliance.salesforce.com/en/trust
e-privacy-verified-seal
- Scoring:
oMost (over 80%) owned operations are certified to widely
accepted standards – company stated that they have
certifications of widely recognized standards and covers
majority or all their operations (80-100% of the total
operations)
o Some (over 20% and below 80%) owned operations are
certified to widely accepted standards – company stated
that they have certifications of widely recognized standards
and covers only a number of their operations (20-80% of the
total operations)
o Few (less than 20%) owned operations are certified to
widely accepted standards – company stated that they
have certifications of widely recognized standards and
covers only a few of their operations (less than 20% of the
total operations)
o Evidence of certification but scope not defined – company
stated that they have certifications of widely recognized
standards, but scope is unknown/unclear
o Company intends to pursue widely accepted certification –
the company has no certification as of the current year, but
they are aiming for a certification
o No evidence – no certification/disclosure
JP IMI
o When there is no disclosure on the company’s website, you
can double-check the following websites to see if the
company has obtained any certifications:
• ISO 27001
▪ (Japanese)
https://www.jab.or.jp/system/iso/search/
(English)
▪
https://www.jab.or.jp/en/system/iso/searc
h/
• TRUSTe
▪ (Japanese) https://www.truste.or.jp/more/
• Privacy Mark
▪ (Japanese)
https://entity-search.jipdec.or.jp/pmark
• Regulations
▪ Act on the Protection of Personal
Information (個人情報保護法)
▪ Basic Act on Cyber Security (サイバーセキュ
リティー基本法)
Type of certification
• Definition: This data point refers to the certification the company has
obtained regarding privacy & data security.
N/A = long text
• Keyword(s):
• ISO 27001, ISO-27001, ISO27001, TRUSTe, JIS Q 15001, JIS Q15001, SSAE
16 SOC 2, SOC2, Privacy Mark
- Common certifications are ISO 27001, TRUSTe, JIS Q 15001, SSAE 16
SOC 2, Privacy Mark
most recent status, rather than taking certification from years ago as
granted (Example: ISO27001 is only valid for three years). Therefore,
we should only give the highest credit (external independent audit) if
there’s evidence of company maintaining/renewing its certification
- Do not give a score if the company only aligns, follows, adheres to the
standards of a certification. It must be explicitly stated by the company
that they are certified to the certification mentioned
• Do not give a mark for general statements on
TRUSTe certification. Only consider CLEAR and
EXPLICIT certifications. Check what the TRUSTe
certification covers; it may not be all operations or
even all websites. Do not give credit if the
https://compliance.salesforce.com/en/truste-
- Scoring:
o List the certifications that the company has on external
standards for Privacy and Data Security
Practices – Supply Chain

Extent of data protection and/or privacy programs covering suppliers and
business partners
• Definition: This data point provides information on extent of data
protection and/or privacy programs covering suppliers and business
partners. We focus here on relevant business partners/suppliers that
handle or have access to data/network.
(a) Yes - inspections are conducted to verify their compliance
(b) Yes - they are required to have data protection policies or abide by the
company’s policy
(c) No Evidence
• Keyword(s):
Supplier privacy, privacy code, privacy program, TRUSTe
- We focus on relevant business partners/suppliers that handle or have
access to data/network.
- Audits/compliance monitoring/due diligence can also be considered in
this data point if inspection/s were not the words used by the company.
- Scoring:
o Yes - inspections are conducted to verify their compliance
– if the company has inspections conducted for third
parties/suppliers/business partners on their compliance
regarding the company’s data protection/privacy programs
o Yes - they are required to have data protection policies or
abide by the company’s policy – if the company’s third
parties/suppliers/business partners should abide by the
company’s data protection/privacy programs or if they
should have data protection policies;
• if the company has a TRUSTe certification, give this
as default score if there are no disclosures that can
merit the highest score.
o No Evidence – no disclosure

China A
- Industry: Bank
- Default Scoring: Yes - they are required to have data protection
policies or abide by the company’s policy
- Source: CBRC guidance www.cbrc.gov.cn/
- Special note: CBRC have issued mandatory guidance specific how
banks should manage technology service outsourcing risks, data
security management policies included in the guidance
- Guidance: For issuers with TRUSTe certification,
- Scoring: give credit for Yes - they are required to have data
protection policies or abide by the company’s policy
▪ https://compliance.salesforce.com/en/truste-
directory/
Practices – Products & Services

Privacy enhancing technologies and initiatives Commented [ACJ77]: Pending to Content:
• Definition: This data point provides information on company's privacy
Software & Services - Content to check on their end if
enhancing technologies and initiatives. company disclosure only mentioned commitments on
• Dropdown choices: privacy by design
(a) Data protection safeguards integrated into product & service
development
(b) Initiatives developed to protect and empower customers/users
(c) Basic education towards customers/users on how to protect
themselves online
(d) No evidence
• Keyword(s):
Data protection technology, initiative for data, initiative for privacy, privacy
initiative, privacy-enhancing technology, data protection technologies,
privacy-enhancing technologies
- This indicator is user/customer centric; we look at how the company
enhances the privacy and data security features of its
products/services to make them safer to use and develops initiatives
and awareness to empower and benefit customers/users’ data
protection online
- Scoring:
o Data protection safeguards integrated into product &
service development – score if the company has data
protection programs/efforts/assessments when they are
developing their products & services
• Data protection safeguards: Privacy and security
are embedded, by default into the architecture,
engineering process, design, and construction of
product/services (e.g., commits to applying Privacy
by Design principles, privacy impact assessment
conducted on existing services/products or before
developing new services/products).
o Initiatives developed to protect and empower
customers/users – score if the company has initiatives on
providing customers more tools/systems for protection
• Initiatives: Advanced tools provided to customers to
enhance their protection online. Initiatives can be
quite industry specific (e.g., Privacy Dashboard, Do
Not Track feature or incognito browsing for
browsers, partnerships with external
organizations/academic institutions to enhance
customers and users’ protection online).
o Basic education towards customers/users on how to
protect themselves online – score if the company
provides education/information to customers/consumers
on how to protect themselves online
• Education: limited tips for customers are available
on company's website (e.g., guidance to improve
password complexity, etc.)
Product Carbon Footprint

This issue evaluates the extent to which companies may face higher input or
production costs for carbon-intensive products due to volatile energy costs in a
carbon-constrained world. Scores are based on companies’ reliance on carbon-
intensive products; and efforts to measure and reduce the carbon footprint of their
supply chains.
Sources:
CDP – Climate Change, TCFD and Sustainability Section of Company Website for
Programs.
Risk Management
Extent of product carbon footprint assessments
• Definition: Indicates if the company evaluates its product's carbon
footprint
(a) Carbon footprint is calculated for all products
(b) Carbon footprint is calculated for core products
(c) Carbon footprint is calculated only for few products (anecdotal cases)
(d) Company indicates having carbon footprint assessment systems, but
does not specify the scope of coverage
(e) No evidence
• Keyword(s):
‘emission’ ‘energy’, ‘footprint’, ‘carbon’
- Scoring:
o Carbon Footprint Calculated for All Products
• Retail – Consumer Discretionary and Consumer
Staples – company evaluates GHG emissions
throughout supply chain for all products
• Household & Personal Products and Household
Durables – company evaluates GHG emissions
throughout all stages of the supply chain for more
than 80% of its product portfolio.
o Carbon footprint is calculated for core products – company
evaluates GHG emissions throughout supply chain for
main/flagship products/ingredients. This option is reserved
for the companies with the most advanced foot printing
systems. If you come across a company that calculates
carbon emissions by supply chain stage rather than
product, select this option when the company reports that it

calculates upstream emissions for all key raw materials.
o Carbon footprint is calculated only for few products
(anecdotal cases) – company evaluates GHG emissions
throughout supply chain for only a few products or not
specified.
• General Procedure – This is the option that we
normally select for companies that use the Cool
Farm Tool and Fieldprint Calculator.
Staples – This is the option that we normally select
for companies that are part of the Sustainable
Apparel Coalition and SCAP.
If a company that calculates carbon emissions by supply
chain stage rather than product, select this option when the
company reports that it calculates upstream emissions for
some of its key raw materials.
o Company indicates having carbon footprint assessment
but doesn't specify scope – Only choose this if the company
mentions lifecycle assessment/carbon foot printing but
doesn’t say which products are included in the assessment.
• Note for Retail – Consumer Discretionary – don't
choose this if the company only reports emissions for
transportation/stores
o No evidence
Staples – choose this if the company does not
measure carbon emissions or (if Retail – Consumer
Discretionary) only reports emissions for its own
operations (stores/transportation) but not for its
supply chain
Assessment of energy consumption and/or carbon emissions of suppliers

• Definition: Indicates if the company track the energy consumption and/or
carbon emissions of its suppliers.
(a) All suppliers submit carbon and/or energy use data
(b) Core or largest direct suppliers submit carbon and/or energy use data
(c) Only a few direct suppliers submit carbon and/or energy data
(anecdotal cases)
(d) General statement that suppliers are "requested" to submit such data
(e) No
• Keyword(s):
‘emission’ ‘energy’, ‘footprint’, ‘carbon’
- Scoring:
o All suppliers submit carbon data – this is self-explanatory.
It is highly unlikely that this option will be chosen.
o Core or largest direct suppliers submit carbon data – given
that the majority of this industry’s carbon footprint is in raw
materials production and manufacturing, ONLY choose this
option if the largest and most important raw materials
farmers are required to submit carbon data. Evidence of
using the Cool Farm Tool and Fieldprint Calculator would
qualify for this option.
o Few direct suppliers submit carbon data – given that the
majority of this industry’s carbon footprint is in raw
materials production and manufacturing, ONLY choose this
option if a few key raw materials suppliers (e.g., cotton
growers) and manufacturers are required to submit carbon
data. Alternatively, if a company reports a case study of one
supplier and it is not clear if the company has made the
same efforts with the other suppliers, choose this option.
o General statement that suppliers are "requested" to submit
such data – The company is vague about the scope of its
carbon/energy measurement efforts but there is evidence
that it is tracking emissions/energy used in its raw materials
suppliers and/or manufacturers.
o No – No evidence of carbon footprinting or energy use
measurement OR only tracks carbon/energy of its own
operations (own manufacturing facilities for TALG and
stores for Retailers)
Targets on measuring upstream carbon emissions

• Definition: Indicates the company's target on measuring upstream carbon
emissions
(a) The company has already calculated the carbon footprint of its core
products and production stages and has a plan for impact reduction
(b) The company plans to expand its product footprint calculation to
include all core products or include other stages
(c) The company plans to initiate carbon footprint assessment for its
products or production stages
(d) No targets
• Keyword(s):
‘emission’ ‘energy’, ‘footprint’, ‘carbon’, ‘target’
- To consider in ‘Average level of SME finance’ option, check the
Issuer Country of Domicile in the below list. If country of domicile
is not included in the list, use the guidelines under Scoring section.
- Scoring:
o The company has already calculated the carbon footprint
of its core products and production stages and has a plan
for impact reduction – The company conducted lifecycle
assessment for core products/identified key agricultural
raw materials' footprint AND has a quantitative carbon
reduction target for its agricultural supply chain.
o Plans to expand its product carbon footprint to include all
core products or other stages – the company already
calculates the total carbon footprint of some core products
AND plans to extend carbon footprinting efforts BUT NO
quantitative carbon reduction target for its agricultural
supply chain
• Retail – Consumer Discretionary – evidence that the
company already calculates the total carbon
footprint of some products AND manufacturers and
plans to extend carbon footprinting efforts to other
products or to include raw materials suppliers
and/or manufacturers or retailers
o The company plans to initiate carbon footprint assessment
for its products or production stages – The company has
only calculated GHG emissions for own
facilities/transportation, no lifecycle assessment for any
products. However, there is evidence that the company will
soon calculate GHG emissions throughout the supply chain.
Also choose this option if the company has recently signed
up to an initiative but has not initiated footprinting just yet.
If you select this option, please make sure that you have not
chosen “Carbon Footprint Calculated for All/Core/Few
Products” for the first question (Extent of product carbon
footprint assessments).
Risk Management – Company assesses the carbon impact or

intensity of the following upstream stages
Evidence carbon or energy intensity assessment of raw materials
production
• Definition: Indicates the company's carbon assessment/evaluation and/or
if there is a disclosure about carbon emission at raw materials production
stage.
(a) Yes
(b) No
(c) Not Disclosed
• Keyword(s):
‘emission’ ‘energy’, ‘footprint’, ‘carbon’, ‘scope 1’,’scope 2’
- The company explicitly measures the carbon emissions at raw
material production and sourcing stage
o Note that while some issuers report Scope 3, the coverage
might be limited to a small portion of indirect emissions.
Please make sure that reported Scope 3 figure covers
emissions from purchased goods and services.
- CDP can be used as a source of this data point as this is part of
CDP questionnaire.
o Consumer Staples (Packaged Foods and Meats/Retail-
Food & Staples
• CDP - C6.5 - Purchased goods and services
• make sure that it covers majority of suppliers-more
than 50%
Evidence carbon or energy intensity assessment of manufacturing
operations, including suppliers
if there is a disclosure about carbon emission at manufacturing operations
(including suppliers) stage.
(a) Yes
(b) No
(c) Not Disclosed
• Keyword(s):
- The company explicitly measures the carbon at the production

stage.
- For manufacturers, please check if the company measures Scope
1 and 2 emissions
- For retailers, please check if the company measures Scope 3
emissions for purchased goods and services
o Private label is only used by retailers, these are produced by
third-party manufacturers for the retailers. The retailer then
market those products as their own brands-example is
Kirkland by Costco. With that logic, private label terms
should only be associated with retailers
CDP questionnaire.
o Consumer Staples (Packaged Foods and Meats/Retail-
Food & Staples
• Please check CDP - C6.5-Purchased goods and
services for Retail-Food and Staples. Make sure that
it covers majority of suppliers-more than 50%
• For Packaged Foods and Meats, make sure that the
company measures Scope 1 and 2 emissions
Evidence carbon or energy intensity assessment of transportation and

logistics operations
if there is a disclosure about carbon emission at transportation and
logistics stage.
(a) Yes
(b) No
(c) Not Disclosed
• Keyword(s):
- The company explicitly measures the carbon emissions at raw
material production and sourcing stage:
o Check if the company measures emissions from its own
transportation and logistics fleet. Make sure that Scope 1
emissions account for company vehicles.
o Depending on the company’s business model, some may
report scope 3 emissions from upstream transportation and
distribution. Basically, transfer of goods and services from

the supplier to the company.
CDP questionnaire.
Evidence carbon or energy intensity assessment of distribution and store

operations

if there is a disclosure about carbon emission at distribution and store
operations stage.
(a) Yes
(b) No
(c) Not Disclosed
• Keyword(s):
- The company explicitly measures the carbon at the distribution
stage and store operations.
- This datapoint is mostly applicable for retailers and distributors
since these issuers are highly involved in store and distribution
activities.
o NOTE: If company doesn’t have a store operation or they’re
a B2B operations or a manufacturer of raw materials for
brands in that case, they don’t have a store operation. Then
this should be scored as No Value.
CDP questionnaire.
Risk Management – Company has carbon or energy reduction

programs at the following stages
Extent of carbon or energy reduction programs in raw materials
production, including suppliers
• Definition: Indicates the company's carbon or energy reduction program at
raw materials production and sourcing stage.
(a) All or core product
(b) Some products (anecdotal cases)
(c) General statement

(d) No
• Keyword(s):
‘emission’, ‘energy’, ‘footprint’, ‘carbon’, ‘BCI’, ‘organic cotton’, ‘LWG’, ‘FSC’,
‘organic chemicals’
CDP questionnaire.
- Scoring:
o All or core products – The company is giving a statement
and the facts for all or core raw materials and their
commitments as well.
o Some products (anecdotal cases) – The company is giving
a statement and the facts for some of the core raw
materials and their commitments as well.
o General statement – A General Statement with no details
on reducing the energy for raw material process is give
Extent of carbon or energy reduction programs in manufacturing

operations, including suppliers' operations
manufacturing stages
(a) All or core production facilities
(b) Some facilities (anecdotal cases)
(d) No
• Keyword(s):
‘emission’, ‘energy’, ‘footprint’, ‘carbon’, ‘solar’, ‘photovoltaic’, ‘renewable
energies’, ‘biofuel’
- Note for manufacturers: Confirm first if the company have a Private
Label Brand or a B2B operation or if the company have a store/retail
operation.
o If company doesn’t have a store operation or they’re a B2B
operations or a manufacturer of raw materials for brands in
that case, they don’t have a store operation.
o Hence, the last datapoint “Extent of carbon or energy
reduction programs in distribution centers / store
operations” should be No Value

CDP questionnaire.
- Scoring:
o All or core production facilities – A commitment with facts
provided on all operations are given
o Some facilities (anecdotal cases) – A commitment with
facts provided on certain operations are given
o General statement – A commitment with no facts and
proofs is provided to reduce energy at the operations level
Extent of carbon or energy reduction programs in transportation and

logistics stages
transportation and logistics stages.
(a) Improvements in fleet, routes, AND load/packaging optimization
(b) Improvements in fleet, routes, OR load/packaging optimization
(d) No
• Keyword(s):
‘emission’, ‘energy’, ‘footprint’, ‘carbon’, ‘sea routes’, ‘transport’, ‘packaging’,
‘FSC’, ‘rail roads’
CDP questionnaire.
- Scoring:
o Improvements in fleet, routes, AND load/packaging
optimization – A statement with facts on the improvement
on both fleet routes and packaging is given.
o Improvements in fleet, routes, OR load/packaging
optimization – A statement with facts on improvement on
either fleet routes or packaging is given
o General statement - A commitment with no facts and proofs
is provided to reduce packaging and transport level Below
average level – if there are any search results for ‘SME’ or
any other related keywords.
Extent of carbon or energy reduction programs in distribution centers /

store operations
distribution centers / store operations.
(a) All or most stores and distribution centers
(b) Some stores/distribution centers (anecdotal cases)
(c) General Statement
(d) No
• Keyword(s):
‘emission’, ‘energy’, ‘footprint’, ‘carbon’, ‘LED lightings’, ‘sensors’
CDP questionnaire.
- NOTE: if the company is a B2B operation or doesn’t have any
store/retail operation this should score as No Value.
- Scoring:
o All or most stores and distribution centers – A commitment
with facts provided on all or most is given
o Some stores/distribution centers (anecdotal cases) – A
commitment with facts provided on certain facilities is
given
o General statement – A commitment with no facts and
proofs is provided to reduce energy at store and distribution
center
Practices – Policies and Practices Commented [ACJ78]:
Scope of carbon footprint assessments across product portfolios Pending with Market Experts
• Definition: Indicates the scope of carbon footprint assessments across
Commented [LRA79R78]: Which one? For CN
product portfolios analysts?
(a) Lifecycle assessment for all products
(b) Lifecycle assessment for core products
(c) Lifecycle assessment only for a few products
(d) Scope of carbon footprinting unknown or limited to operational level
(e) No evidence
• Keyword(s):
‘lifecycle assessment’
- Answer if the company is a China A issuer.
Programs to reduce carbon emissions and/or improve energy efficiency

of its supply chain (upstream)
• Definition: Indicates the company’s program/s to reduce carbon
emissions and/or improve energy efficiency of its supply chain (upstream)
(a) Programs across all relevant products
(b) Programs across selected relevant product
(c) General statement to reduce carbon emission and/or improve energy
efficiency of its products at the upstream stage
(d) No evidence
• Keyword(s):
‘energy efficient’, ‘energy saving’, ‘maintenance’, ‘green’, ‘clean production’
- Scoring:
o Programs across all relevant products – If the company
takes initiatives in improving its energy efficiency for all
products and across all production plants through green
and renewable energy consumption, green factories, and
other large-scale energy-saving/emission reduction
measures directly associated with the production/operation
process.
o Programs across selected relevant product – If the
company takes initiatives in improving its energy efficiency
for a certain product or a production plant through
purchasing new energy-saving equipment, renovating
factories, and other large-scale energy-saving/emission
reduction measures directly associated with the
production/operation process.
o General statement to reduce carbon emission and/or
improve energy efficiency of its products at the upstream
stage – If the company takes initiatives in improving its
energy efficiency through upgrading old equipment, regular
maintenance of production equipment, and other energy-
saving measures directly associated with the
production/operation process
Programs to reduce carbon emissions and/or improve energy efficiency

of its products' end use (downstream)
emissions and/or improve energy efficiency of its products' end use
(downstream)
(a) Programs across all relevant products
(b) Programs across selected relevant products
(c) General statement to reduce carbon emission and/or improve energy
efficiency of its products at downstream stage
(d) No evidence
• Keyword(s):
‘environment friendly’, ‘green product’, ‘biodegradable’, ‘efficient’, ‘recycle’
- Scoring:
o Programs across all relevant products – If ALL products
manufactured by the company are 100% biodegradable,
energy saving, non-polluting, non-hazardous, and are
reusable or recyclable.
o Programs across selected relevant products – If the
company generates partial revenue or is involved in
manufacturing products that are biodegradable, energy
saving, non-polluting, non-hazardous, and are reusable or
recyclable.
o General statement to reduce carbon emission and/or
improve energy efficiency of its products at downstream
stage – General statement about the company
manufacturing energy efficient, clean, and environment-
friendly products.
Carbon reduction incentives for Tier 1 suppliers (manufacturing)

• Definition: Indicates if the company has carbon reduction incentives for
Tier 1 suppliers (manufacturing)
(a) Carbon or energy performance is a factor in selecting new suppliers or
awarding new contracts
(b) Supplier code of conduct encourages or recommends carbon reduction
(c) No evidence
• Keyword(s):
‘reduction’, ‘supplier’, ‘criteria’, ‘selection’

- Scoring
o Carbon or energy performance is a factor in selecting new
suppliers or awarding new contracts – If the company
screens suppliers based on their carbon reduction
initiatives and recognizes such suppliers by awarding
contracts or other lucrative benefits
o Supplier code of conduct encourages or recommends
carbon reduction – If the company states that suppliers
with carbon reduction initiatives will be preferred over
regular suppliers
Carbon reduction incentives for Tier 2 and 3 suppliers (raw materials)

• Definition: Indicates if company has carbon reduction incentives for Tier 2
and 3 suppliers (raw materials)
(a) Only certified materials are purchased (e.g., FSC, RSPO)
(b) Certified or sustainably produced materials are preferred
(c) No evidence
• Keyword(s):
‘reduction’, ‘supplier’, ‘raw materials’
China A
- China A guideline: This data point is only scored if issuer is China A
Practices – Company assesses the carbon impact or intensity

of the following stages Commented [ACJ80]: Pending with Market Experts
Tracking carbon emissions on an ongoing basis for Tier 2 and 3 suppliers: Commented [LRA81R80]: This whole section?
raw material production/agriculture
• Definition: Indicates if the company tracks/assess carbon
impact/intensity/ emission of raw material production/agriculture
(a) All critical suppliers (i.e. all suppliers, which form top 80% by cost of
supplies)
(b) Selected critical suppliers (i.e. between 30 and 80% of critical suppliers)
(c) No evidence
• Keyword(s):
‘emission’, ‘energy’, ‘footprint’, ‘carbon’, ‘agriculture’, ‘raw material’
China A
Tracking carbon emissions on an ongoing basis for Tier 1 suppliers:

manufacturing operations
impact/intensity/ emission at manufacturing operations
supplies)
(c) No evidence
• Keyword(s):
‘emission’, ‘energy’, ‘footprint’, ‘carbon’, ‘manufacturing’
China A
Tracking carbon emissions on an ongoing basis for transportation and

logistics
impact/intensity/ emission at transportation and logistics stage
supplies)
(c) No evidence
• Keyword(s):
‘emission’, ‘energy’, ‘footprint’, ‘carbon’, ‘transportation’, ‘logistics’
-
Read the options carefully and choose the best option that describe
China A
Tracking carbon emissions on an ongoing basis for the downstream stage

(product use)
impact/intensity/ emission at downstream stage (product use)
(a) Yes
(b) No evidence
• Keyword(s):
‘emission’, ‘energy’, ‘footprint’, ‘carbon’, ‘downstream’
- Scoring:
o Yes – if the company publicly discloses tracking the
emissions of its products on a regular basis
China A
Practices – Company has carbon or energy reduction programs

at the following stages Commented [ACJ82]: Pending with Market Experts
Emissions or energy reduction program for Tier 2 and 3 suppliers: raw

material production/agriculture
• Definition: Indicates if the company has emissions or energy reduction
program for Tier 2 and 3 suppliers at raw material production/agriculture
supplies)
(c) No evidence
(d) No
• Keyword(s):
‘emission’, ‘energy’, ‘footprint’, ‘carbon’, ‘agriculture’, ‘raw material’

China A
Emissions or energy reduction program for Tier 1 suppliers:

manufacturing operations
program for Tier 1 suppliers at manufacturing operations
suppliers)
(b) Selected critical suppliers (i.e. between 30% and 80% of critical
suppliers)
(c) No evidence
• Keyword(s):
‘supplier’, ‘planning’, ‘energy’, ‘production’
- Scoring:
o All critical suppliers (i.e. all suppliers, which form top 80%
by cost of suppliers) – If the company is directly involved in
the energy reduction programs of most of its suppliers or
takes initiatives to manage supplier energy consumption
reduction through investments, planning, or consultancy.
o Selected critical suppliers (i.e. between 30% and 80% of
critical suppliers) – If the company is directly involved in the
energy reduction programs of some of its suppliers or takes
initiatives to manage supplier energy consumption
reduction through investments, planning, or consultancy.
Emissions or energy reduction program for transportation and logistics

program for transportation and logistics operations
(a) Improvements in fleet, routes, and load/packaging optimization
(b) Improvements in fleet, routes, or load/packaging optimization
(c) General statement regarding improvements in emission or energy
reduction program for transportation and logistics
(e) No evidence
• Keyword(s):
‘transport’, ‘fleet’, ‘optimization’, ‘logistics’, ‘packaging’, ‘eco’,
- Scoring:
o Improvements in fleet, routes, and load/packaging
optimization – If the company adopts green transport
initiatives such as use of electronic vehicles, improved fleet
routes, energy optimization, and undertakes green logistics
programs such as eco-friendly and biodegradable
packaging
o Improvements in fleet, routes, or load/packaging
optimization – If the company adopts green transport
initiatives such as use of electronic vehicles, improved fleet
routes, or undertakes green packaging programs
o General statement regarding improvements in emission or
energy reduction program for transportation and logistics
– If the company disclosed general statements on taking
initiatives to improve emission or energy reduction
programs for transportation and logistics
China A
Emissions or energy reduction program for the downstream stage

(product use)
program for the downstream stage (product use)
(a) Yes
(b) No evidence
• Keyword(s):
‘environment friendly’, ‘green product’, ‘biodegradable’, ‘efficient’, ‘recycle’
- Soring:
o Yes – if “Programs to reduce carbon emissions and/or
improve energy efficiency of its products' end use
(downstream)” is not at ‘No evidence’
China A
Targets Commented [ACJ83]: Pending with Market Experts
Emissions or energy reduction target for Tier 2 and 3 suppliers: raw

material production/agriculture
• Definition: Indicates if the company has emissions or energy target for
Tier 2 and 3 suppliers at raw material production/agriculture.
supplies)
(c) No evidence
• Keyword(s):
‘emission’, ‘energy’, ‘footprint’, ‘carbon’, ‘raw material’, ‘agriculture’
China A
Emissions or energy reduction target for Tier 1 suppliers: manufacturing

operations
• Definition: Indicates if the company has emissions or energy target for Tier
1 suppliers at manufacturing operations.
supplies)
(d) No evidence
• Keyword(s):
‘emission’, ‘energy’, ‘footprint’, ‘carbon’, ‘manufacturing’
China A
- Industry/ Sub-Industry: Automobile Manufacturer; Apparel,
Accessories & Luxury Goods; Textiles
- Scoring: Selected critical suppliers (i.e. between 30 and 80% of

critical suppliers)
- Source:
o Automobile Manufacturer
The required cap by 2025 for fuel emissions for generic
passenger vehicles is planned to be 4 L/100km (95 g
CO2/km).
• http://www.miit.gov.cn/
• http://www.miit.gov.cn/
o Textiles and Apparel industry
Although the draft for Dyeing Industry Standards is still
under public consultation (until 28 July), the draft (expected
to be enacted in 2017) includes the cap for energy
consumption for manufacturing of different type of textile
materials. Example: energy consumption for cotton and
linen has to be less than 30 kg standard coal per 100 meter
product according to MIIT (Ministry of Industry and
Information Technology).
• http://zmhd.miit.gov.cn:8080/opinion/noticedetail.d
o?method=notice_detail_show&noticeid=1811
Emissions or energy reduction target for transportation and logistics

• Definition: Indicates if the company has emissions or energy target for Tier
1 suppliers at transportation and logistics
(a) Targets around fleet, route, storage AND load optimization
(b) Targets around either fleet, route, storage OR load optimization
(c) General statements regarding emissions or energy reduction target for
transportation and logistics
(e) No evidence
• Keyword(s):
‘emission’, ‘energy’, ‘footprint’, ‘carbon’, ‘transportation’, ‘logistics’
China A
Emissions or energy reduction target for the downstream stage

• Definition:
(a) Yes
(b) No evidence
• Keyword(s):
‘emission’, ‘energy’, ‘footprint’, ‘carbon’, ‘downstream’
China A
Performance – Downstream emissions management

Downstream: Efficiency ratio Commented [LRA84]: Pending query with Content
•Definition: Indicates company’s downstream efficiency ratio. Team. Below query is available in Adhoc Teams
Channel.
•Dropdown choices:
N/A – Numeric Value Kindly provide guidance for this data point. Upon
checking, there's no published data in Capture. Do we
• Keyword(s):
still update this field?
‘efficiency ratio’
- Do not add row if there’s no evidence found.
China A
China A guideline: This data point is only scored if issuer is China A
Product Safety & Quality

This issue evaluates the extent to which companies may face product recalls or lost
customer trust due to product quality concerns. Scores are based on exposure to
products with greater incidence of safety issues; efforts to ensure product safety and
quality through the supply chain, operations, and marketing; recalls, warning letters,
warranty payments; and controversies.
Casinos & Gaming:

For the Casinos and Gaming industry, the PSQ KI assesses the responsible gaming
policies and programs of a company. Hence, all data points which will be answered
for the industry under this KI should refer to responsible gaming.
Retail - Consumer Discretionary

PSQ is added as a company-specific KI for companies under Retail - Consumer
Discretionary if they have significant involvement (at least 20% of total revenue) in
the ff:
1. Food production/retailing and
2. Pet food/drug product manufacturing/retailing.
We also add PSQ if the company has significant involvement in liquor/alcohol

manufacturing or retailing (at least 20% of total revenue). In this case, we only
answer the Responsible Marketing section.
Manufacturing and handling

Existence of contingency plans/mitigation control systems
• Definition: Indicates if the company has a policy on bribery and anti-
corruption in place and the scope of that policy. These indicators assesses
whether the company has systems in place to mitigate risks that
unexpected disruptions in manufacturing operations or the supply chain
will cause quality or safety problems and/or production disruptions.
The indicator can relate to either 1) supply risk or 2) internal manufacturing

risk. The idea is that companies with mitigation/contingency plans are
better positioned to meet consumer demand in a quality manner, while
reducing the possibility of loss in operational efficiencies and financial
losses compared to companies with no contingency plans/mitigation
systems. Companies that have contingency plans to ensure that products
are in stock, reliable, and safe are better placed to minimize risks of
unexpected disruptions in supply of materials and minimize the risks of
encountering quality problems compared to companies with no such
systems.
1) Supply risk associated with company dependency on third party for

service/materials that are critical to ongoing flow of company operations.
Supply risk can be due to factors including financial instability, capability
to produce a good/service in a quality manner, or impact of natural
disasters.
2) Internal manufacturing risk is associated with the risk that companies'

own manufacturing capabilities may be affected by quality problems that
could compromise the quality and flow of goods or service to customers
and lead to unsafe and/or defective products/goods. Internal
manufacturing risk can be due to factors that may include (but are not
limited to) compromised quality control and quality assurance systems,
natural disasters, compromised sterility, or lapses in manufacturing
processes.
(a) Comprehensive and systematic risk mitigation process (e.g., dual
sourcing, back-up manufacturing sites)
(b) Mitigation systems in place for key products only
(c) Some evidence of contingency plans but limited details on scope
(d) No evidence
• Keyword(s):
应急预案 contingency plan
- Scoring:
o Comprehensive and systematic risk mitigation process
(e.g. Dual sourcing, back-up manufacturing sites) – The
company maintains comprehensive contingency plans to
mitigate risks that unexpected disruptions in its operations
or supply chain could lead to quality or safety issues
procurement policies and risk management practices,
including systematic risk mitigation processes such as
[appropriate use of dual or multiple suppliers / maintaining
back-up manufacturing sites].
o Mitigation systems in place for key products only – While
the company maintains risk mitigation systems to help
ensure that unexpected disruptions in its operations or
supply chain will lead to quality or safety problems, such as
[provide examples of supplier-or own manufacturing-related

systems], these processes are in place only for key
products.
o Some evidence of contingency plans but limited details on
scope – While we see evidence that the company maintains
risk mitigation systems to help ensure that unexpected
disruptions in its operations or supply chain will lead to
quality or safety problems [provide examples of supplier- or
manufacturing-related systems if available], the company
provides limited details on the scope of these processes.
Some evidence of contingency plans but limited details on
scope = While we see evidence that the company maintains
o No evidence – We see no evidence that the company
maintains risk mitigation systems to help ensure that
unexpected disruptions in its operations or supply chain will
lead to quality or safety problems.
- General Procedure is also applicable to
o Automobiles, Auto Components and Aerospace & Defense

Industry Guidelines
o Sub-Industry: Casinos & Gaming
o Default Scoring: Do not answer, leave as No Value
o Sector: Real Estate

o Specific Guidance: not applicable
o Sector: Retail - Consumer Discretionary

o Specific Guidance: For Retail - Consumer Discretionary, although
most companies are just retailers, be mindful of those with private
labels. Some of these companies also do the manufacturing of these
private labelled products, themselves, or they rely on third party
manufacturing sites (outsource production from third party
manufacturing sites).
o Industry: Hotels & Travel
o Specific Guidance:
▪ For cruise lines and ferry operators, please leave this as 'No
Value', but if it has been previously scored, keep them as they
were.
▪ For amusement park operators, please refer to the scoring
guidance below:
• Comprehensive and systematic risk mitigation process - if
the company has comprehensive risk mitigation strategies,
eg. early identification of risks, action plans in case of
incidents, appropriate control process, product
inspections, maintenance and refurbishment
• Mitigation systems in place for key products only - with
some details of risk mitigation strategies, but is not
proactive in nature (ie. No procedures or action plans in
place to identify potential risks)
• Some evidence of contingency plans but limited details on
scope - general statements of contingency plans
• No evidence
o Sub-Industry: Health Care Facilities, Managed Health Care

o Sub-Industry: Health Care Services

o Specific Guidance: Check if applicable to the company Commented [LRA85]: Pending with Content Team –
to provide examples
o Industry: Restaurants
China A
o 应急预案 (contingency plan)
o contingency plans to ensure that products are in stock,
reliable, and safe
• maintained a supply base that are ready to reduce
dependency on third party for service/ materials
• maintained flexibility of its own Internal
manufacturing capabilities
• Participating in industry organizations to detect
potential sourcing, and promote industry
development
• Form an industry-university-research ecological

alliance to achieve technological self-reliance and
quality improvement
Extent of certification to a widely accepted product safety / quality

standard (e.g. HACCP, ISO 9001, or equivalent)
• Definition: This data point refers to the extent of widely accepted product
safety certification
(a) Most (over 80%) owned facilities are certified to widely accepted
standards
(b) Some (over 20% and below 80%) owned facilities are certified to widely
accepted standards
(c) There is some evidence of certification
(d) Few (less than 20%) owned facilities are certified to widely accepted
standards
(e) Company intends to pursue widely accepted certification of owned
facilities
(f) No evidence
• Keyword(s):
'ISO 9001', 'TS 16949', 'ISO/TS 16949', 'certification', 'ISO certification' or
use the certifications indicated in Guidelines for Specific Industry / Market
section.
- If company does not explicitly state scope of certifications, please
check if it can be calculated.
o [Number of properties and/or construction sites certified]
divided by [Total number of properties and/or construction
sites]. Please input figures and sources in Internal Notes
section.
- Scoring:
o Most (over 80%) owned facilities are certified to widely
accepted standards – There is evidence that over 80% of its
operations are certified.
o Some (over 20% and below 80%) owned facilities are
certified to widely accepted standards – There is evidence
that a sizable portion (>20% and <80%) of its operations are
certified.
There is evidence of certification – Company states that it

o
has certification but does not specify scope.
o Few (less than 20%) owned facilities are certified to widely
accepted standards – There is evidence that only a small
portion of its operations are certified.
o Company intends to pursue widely accepted certification
of owned facilities – Company states that it aims to and/or
is in the process of obtaining a widely accepted certification
such as ISO 9001.
o Retail - Consumer Discretionary

Industry Guidelines
o Industry: Pharmaceuticals, Biotechnology

o Keyword(s): ICH Q10 certification
o Sub-Industry: Health Care Facilities

o Keyword(s): The Joint Commission (TJC) certification
o Sub-Industry: Health Care Equipment; Health Care Supplies

o Keyword(s): ISO 13485
o Industry: Food Products, Restaurants, Retail - Food & Staples

▪ Accepted certifications:
• PrimusGFS
• IFS PACsecure
• Global Aquaculture Alliance Seafood
• GLOBALG.A.P.
• Global Red Meat Standard
• Food Safety System Certification 22000 (FSSC 22000)
▪ If the company requires all its suppliers to be certified to GFSI-
benchmarked standards, please choose "Most (over 80%)
owned facilities are certified to widely accepted standards"
o Industry: Automobiles / Auto Components

o Specific Guidance: ISO 9001, TS 16949
o Industry: Aerospace & Defense

o Specific Guidance: ISO 9001, AS 9100

▪ For cruise lines and ferry operators, all companies should be
“Most (over 80%) owned facilities” given that the marine
transport industry is highly regulated, unless the company’s
business is highly diversified, and its cruise and ferry segment
does not comprise over 80% of its entire business.
▪ For amusement park operators, please leave this as 'No
Evidence' for now. The scoring guidance is still evolving.
o Sub-Industry: Managed Health Care

China A
o Search evidence for:
• ISO 9001:2015
• China GB/T 19001-2015
o Note: this is the company’s own operation instead of
supplier certifications.
- Sector: Consumer
o GB/T 19001—2016 (for companies having operations in
China) is an equivalent certification to HACCP and ISO 9001.
Scope of certification against an internally developed product safety /

quality standard Commented [LRA86]: Pending query with Content
• Definition: This data point refers to the scope of certification against an Team. Below query is available in Adhoc Teams
Channel.
internally developed product safety/ quality standard
• Dropdown choices: [Vendor Query]
(a) Most (over 80%) owned facilities are certified to an internally developed Can you provide an example for ‘Scope of certification
against an internally developed product safety/quality
standard standard’? Also, are there any specific keywords for
(b) There is evidence of certification finding evidence for this data point?
(c) Few (less than 20%) owned facilities are certified to an internally Commented [SAM87R86]: Unresolved; requires
developed standard (d) No evidence response
(d) Company intends to pursue an internally developed certification Commented [LRA88R86]: Pending with Content
scheme of owned facilities
(e) No evidence
• Keyword(s):
internal, internal standard, internal certification, certification
o Industry: Casinos & Gaming

o Keyword(s): Responsible gaming committee, responsible gaming
officer, responsible gaming team
- If company does not explicitly state scope of certifications, please
check if it can be calculated.
o [Number of properties and/or construction sites certified]
divided by [Total number of properties and/or construction
sites]. Please input figures and sources in Internal Notes
section.
- Scoring:
o Most (over 80%) owned facilities are certified to an
internally developed standard – There is evidence that over
80% of its operations are certified to its internal certification
standard.
o There is evidence of certification – Company states that it
implements its own internal certification program but does
not give details on scope of certification for its current
operations.
o Few (less than 20%) owned facilities are certified to an
internally developed standard – There is evidence that only
a small portion of its operations are certified to its internal
certification standard.
o Company intends to pursue an internally developed
certification scheme of owned facilities – The company
states that it aims to and/or is in the process of developing
an internal certification scheme.
o No evidence – There is no evidence of any internal
certification scheme.

Industry Guidelines
o Note: For Casinos and gaming, this data point has been
customized to reflect level of oversight on the company's
Responsible Gaming measures.
o Scoring:
▪ Most (over 80%) owned facilities are certified to an
internally developed standard – score if oversight is on
Board-level committee or C-suite or executive committee
and leave details in the Internal Notes
▪ There is evidence of certification – score if oversight is on
Corporate Social Responsibility/ Sustainability team and
leave details in the Internal Notes
▪ Few (less than 20%) owned facilities are certified to an
internally developed standard – score if oversight is on
Special task force or risk officer and leave details in the
Internal Notes
▪ Company intends to pursue an internally developed
certification scheme of owned facilities – scored this for
Casinos & Gaming, leave details in the Internal Notes
o Industry: Airlines
o Specific Guidance: Certifies own operations to a widely accepted
product safety/ quality standard (e.g., HACCP, ISO 90001, or
equivalent)
▪ if airline implements IATA Operational Safety Audit (IOSA),
score "Most (over 80%...” for all airlines that are IOSA registered"
(check and search issuer:
https://www.iata.org/en/programs/safety/audit/iosa/registry/
)
▪ if airline is a member of IATA (International Air Transport
Association (IATA), score "Most (over 80%...” for all airlines that
are IOSA registered" (check and search
issuer:https://www.iata.org/en/about/members/airline-list/)
▪ otherwise, No Evidence
o Industry: Automobiles
o Specific Guidance: Should be scored. Automobiles have their own
internal quality systems before the ISO certification was
established (e.g., The Toyota Way etc.). These systems can be
considered for this DP.
o Industry: Auto Components

o Scoring: "No Value" for those companies which have a widely
accepted product safety/ quality standard in place: ISO 90001, TS
16949, IATF 16949.
o Industry: Retail - Consumer Discretionary

▪ Retail - Consumer Discretionary follow treatment for Food
retailers. If companies require suppliers to adhere to the GFSI
benchmarked schemes (see list below), this is automatically
scored as "Most (over 80%) owned facilities are certified to
widely accepted standards"
▪ GFSI does not set any of its own food safety standards, it has
recognized 10 food safety standards as meeting minimum food
safety requirements
• PrimusGFS
• IFS PACsecure
• GLOBALG.A.P.
• CanadaGAP
• SQF
• International Featured Standards (IFS)
• BRC Global Standard

o Specific Guidance: Select "No Value" for those companies which
have a widely accepted product safety/ quality standard in place: ISO
90001, TS 16949, or equivalent.

o Specific Guidance: No Value
o Sub-Industry: Health Care Facilities, Managed Health Care,

Pharmaceuticals, Biotechnology
China A
o No evidence if evidence for ISO 9001
o Note: this is the company’s own operation instead of supplier
certifications
- Sector: Consumer
▪ For food manufacturers (including beverage and restaurant
issuers), they shall comply with the GB standards, which are
developed and published by the regulator, to acquire
production and manufacturing license. However, in case the
local issuers only mention GB, but no other policies or
standards adopted, please do not give credits.
Measures and reports quantitative indicators related to service quality

performance or customer protection (e.g. clinical quality reports, customer
surveys)
• Definition: This data point refers to the quantitative indicators related to
service quality performance or customer protection
(a) Detailed, quantitative information on outcomes
(b) General information on outcomes
(c) Yes
(d) No
(e) Not Disclosed
• Keyword(s):
feedback, customer feedback, engagement, stakeholder engagement,
survey, customer survey
消费者满意度调查：customer satisfaction survey, 满意度：satisfaction
rate, 消费者投诉：customer complaints
specific guidance.
- Scoring:
o Detailed, quantitative information on outcomes – Company
discloses quantitative results of customer
feedback/satisfaction surveys.
o General information on outcomes – Company releases
general/broad statement on result of customer
feedback/satisfaction surveys.
o Yes – Company states that it implements customer
feedback surveys.

Industry Guidelines

o Default Scoring: No Value
o Reason: Since Auto Components have lower exposure to end
customers.

o Industry: Retail - Consumer Discretionary

▪ Retail Consumer Discretionary follow treatment for Food
benchmarked schemes (see list below), this data point is scored
based on the ff:
▪ If the company does not report on the outcome of the complaint
system: Yes
▪ If the company does report on the outcomes (depending on the
disclosure): General information on outcomes or Detailed,
quantitative information on outcomes
safety requirements
• PrimusGFS
• IFS PACsecure
• GLOBALG.A.P.
• CanadaGAP
• SQF
o Sub-Industry: Health Care Distributors, Health Care Equipment,

Health Care Supplies, Pharmaceuticals, Biotechnology
o Sub-Industry: Health Care Services, Life Sciences Tools & Services

to provide examples
o Sub-Industry: Health Care Facilities
o Specific Guidance: Look for: quality surveys, clinical data points or
complaints resolution mechanisms
o Industry: Food Products, Retail - Food & Staples

o Specific Guidance: If the company requires all suppliers to obtain
GFSI-benchmarked certifications:
▪ General information on outcomes - Choose this if the company
does report on the outcomes
▪ Yes - Choose this if the company does not report on the
outcome of the complaint system
China A
Key words: 满意度 – satisfaction rate, 消费者满意度调查：customer
satisfaction survey, 消费者投诉：customer complaints
o Scoring:
• Detailed, quantitative information on outcomes
▪ Best Practices: Satisfaction rates,
complaints, and details of areas to be
improved disclosed
• General information on outcomes
▪ Disclose complaints handling rate by
residential/ commercial projects
▪ Disclose customer satisfaction rate by
residential/ commercial tenants
▪ No details of areas to be improved disclosed
• Yes – Some evidence
Conducts quality control / product safety training program for

employees
China A
- Sector: Consumer
o For food manufacturers (including beverage and restaurant
issuers), they should have food/product safety training
programs provided to employee. Suggest carefully looking
for the programs (both frequency and scope).
o Rationale: in Food Safety Law, Chapter 2 Production and
Trade Process Control,
o A food production or trade enterprise shall establish and
improve its food safety management rules, provide food
safety training for its employees…. a food production or
trade enterprise shall employ food safety management
personnel and strengthen the training and assessment of
them.
• 第四十四条食品生产经营企业应当建立健全食品
安全管理制度，对职工进行食品安全知识培训，加
强食品检验工作，依法从事生产经营活动。
• 食品生产经营企业的主要负责人应当落实企业食品
安全管理制度，对本企业的食品安全工作全面负责
。
• 食品生产经营企业应当配备食品安全管理人员，加
强对其培训和考核。 Commented [LRA90]: @Atilano, Cristine Joyce
Frequency of employee training

• Definition: This data point refers to the frequency of employee training
(a) Annual training
(b) Periodic training but frequency is unknown
(c) Training is on an ad hoc as-needed basis only
(d) No evidence
• Keyword(s):
employee training, ISO certification, quality controls, quality management
• General Procedure
- If company has no disclosure but has GMP compliance, score Training
is on an ad hoc as-needed basis only.
- Scoring:
o Annual Training – Select this option if any of the following
conditions are met: the company is ISO 9001/ TS 16949
certified for all (100%) operations, as it will conduct product
testing for all products; or the company states that it
implements annual training for its employees on quality

control and product safety
o Periodic training but frequency is unknown – Select this
option if any of the following conditions are met: the
company is ISO 9001/ TS 16949 certified for <100%
operations, as it will conduct product testing for all
products; or the company mentions that it trains its
employees on quality control and product safety, but no
further details are provided
o Training is on an ad hoc as-needed basis only – Select this
option if any of the following conditions are met: the
company only discloses vague information regarding QMS
(Quality Management System) certification/ not clear
evidence that QMS in place; or the company mentions
employee training on product safety and quality but only in
response to quality issues and/or customer complaints
o No evidence – There is no evidence that the company trains
its employees on product safety and quality.
o Retail - Consumer Discretionary, Automobiles, and Auto
Components Industry
o Applicable to Aerospace & Defense except that it is AS 9100
instead of TS 16949

Industry Guidelines
o Specific Guidance: This data point refers to employee training on
responsible gaming.
o Sector: Health Care except for Managed Health Care

o Default Scoring: Give this minimal credit (Training is on an ad hoc
as-needed basis only) if a company explicitly mentions GMP, ISO
900,1 or ISO 13485

o Industry: Food Products, Retail - Food & Staples, Restaurants

▪ Companies must explicitly disclose frequency. If the company

conducts training but there is no evidence of frequency, please
give the credit "Training is on an ad hoc as-needed basis only.
▪ This datapoint should be aligned with Scope of employee
training.
China A
o Search for:
• Number or percent of employees trained for quality
control and management
o Keywords:
• “质量” – quality
• “员工” – employee
• “培训” – training
- Sector: Consumer
o Follow the generic guidance, also considering GB/T 19001—
2016.
Scope of employee training

• Definition: This data point refers to the scope of employee training
(a) All employees are trained
(b) Most (over 75%) employees are trained
(c) Some employees
(d) No evidence
• Keyword(s):
employee training, scope, program scope, programme scope
- Scoring:
o All employees are trained – Select this option if any of the
following conditions are met: the company is ISO 9001/ TS
16949 certified for all (100%) operations, as it will conduct
product testing for all products; or the company states that
it implements annual training for its employees on quality
control and product safety for all employees (including part-
time and contractors, dealers, etc.)
o Most (over 75%) employees are trained – Select this option
if any of the following conditions are met: the company is
ISO 9001/ TS 16949 certified for <100% operations, as it will
conduct product testing for all products; or the company
states that it implements annual training for its employees

on quality control and product safety for over 75% of
employees (pr all permanent employees)
o Some employees – Select this option if any of the following
conditions are met: the company only discloses vague
information regarding QMS (Quality Management System)
certification/ not clear evidence that QMS in place; or the
company mentions employee training on product safety
and quality but no details on scope or if training is only for
frontline staffs or a limited number of employees)
its employees on product safety and quality.
Components Industry
o Applicable to Aerospace & Defense except that it is AS 9100
instead of TS 16949

Industry Guidelines
o Specific Guidance: Guideline for scoring
▪ All employees are trained - employees including part-time and
contractors, dealers, distributors, retail agents, etc.
▪ Most employees - All permanent employees
▪ Some employees - Frontline staff only or limited number of
employees
▪ No evidence – no disclosure found
o Sector: Health Care except for Managed Health Care

o Default Scoring: Give this minimal credit (o Some employees) if a
company explicitly mentions GMP, ISO 9001, or ISO 13485


▪ Companies must explicitly disclose scope. If the company
conducts training but there is no evidence of scope, please give
the credit "Some employees".
▪ This datapoint should be aligned with Frequency of employee

training.
China A
o Search for:
• Number or percent of employees trained for quality
control and management
o Keywords:
• “质量” – quality
• “员工” – employee
• “培训” – training
- Sector: Consumer
2016.
Product Testing
Extent of product testing capacity
• Definition: Indicates if the company has product testing capacity
(a) In-house testing
(b) Third-party testing
(c) No evidence
• Keyword(s):
In house testing, third party testing, testing, product testing, test
- If a company conducts product testing at its own facility and at the third
party, choose ‘Third-party testing’. Example: The Company
manufactures its products with components and subassemblies
supplied by vendors and assembles and tests each of its products at
the Brisbane, California facility, and at third party contract
manufacturers’ facilities
- Scoring:
o In-house testing – select this option as the company
conducts test on their own products
o Third party testing – select this option as the company
conducts test by a third party
Components Industry

Industry Guidelines
o Sub-Industry: Real Estate

o Industry: Hotels and Travel

o Specific Guidance: For cruise lines and ferry operators, please leave
this as 'No Value', but if it has been previously scored, keep them as
they were.
o Sub-Industry: Health Care Distributors, Health Care Facilities,

Managed Health Care

▪ If there is evidence of product testing but capacity is unclear,
credit should be at least "Third-party testing"
▪ This datapoint should be aligned with Scope of product testing
datapoint
o Industry: Auto Components, Automobiles

o Default Scoring: No value
o Reason: since in-house or third-party testing is covered under ISO
9001/ TS 16949. ONLY SELECT IN CASE THE COMPANY IS NOT
CERTIFIED.

o Reason: since in-house or third-party testing is covered under ISO
9001/ AS 9100. ONLY SELECT IN CASE THE COMPANY IS NOT
CERTIFIED.
China A
o Search for: “检测”- testing, 第三方：third party, 检测能力：
testing capabilities, 实验室：lab/laboratories

o Reference to ISO 9001 certification and audits, or other
specific procedures for third-party testing for under
construction and completed project/process.
o Best practice:
• Completed the ISO 9001 Quality Management
System certification for all regions and applied
annual audit to ensure certificate validity.
• And professional third-party evaluation
organizations are introduced to conduct evaluation
and inspection on residential housing and public
facility projects that are under construction or have
been handed over, to strengthen quality oversight
and improve overall quality.
Scope of product testing

• Definition: Indicates the scope of product testing of the company
(a) Precautionary testing for emerging quality/safety concerns
(b) Selective testing for high-profile quality/safety concerns
(c) No evidence
• Keyword(s):
testing, product testing, test
- Scoring:
o Precautionary testing for emerging quality/safety
concerns – Select this option if the company is ISO 9001/
TS 16949 certified for all (100%) operations, as it will
conduct product testing for all products.
o Selective testing for high-profile quality/safety concerns –
Select this option if the company is ISO 9001/ TS 16949
certified for <100% operations, as it will conduct product
testing for all products.
o No evidence – Select this option if the company only
discloses vague information regarding QMS certification/
not clear evidence that QMS in place.
o Automobiles and Auto Components. Also applicable to A&D
except that it's AS 9100 instead of TS 16949

Industry Guidelines
o Industry: Retail - Consumer Discretionary, Food Products, Retail -

Food & Staples, Restaurants
▪ Retail Consumer Discretionary follow treatment for Food
scored as "Precautionary testing for emerging quality/safety
concerns."
safety requirements
• PrimusGFS
• IFS PACsecure
• GLOBALG.A.P.
• CanadaGAP
• SQF
• -International Featured Standards (IFS)


o Sub-Industry: Health Care Equipment

o Specific Guidance: Selective testing for high-profile quality/safety
concerns - Default threshold for healthcare equipment companies
esp. if they must market their products in the EU.
o Sub-Industry: Health Care Distributors, Health Care Facilities,

Managed Health Care

they were.
China A
o Scoring:
• Precautionary testing for emerging quality/safety
concerns – Precautionary testing: process oriented,
beyond the general procedure of handover testing.
Explicit and detailed evidence of testing in each key
process.
• Selective testing for high-profile quality/safety
concerns – Selective testing if only perform testing
for housing handover
• No Value – Only if any evidence of in-house or
third-party testing is available, with details of
testing results or tracking records disclosed
o Best Practices:
• “Construction quality evaluation is added to the
special quality evaluations of Mechanical &
Electrical (M&E) devices, fitting out, curtain walls
and landscaping works, to focus on project
• Operation safety, operation energy consumption
and functions.”
- Sector: Consumer
2016.
Operations
Collaboration with suppliers to address product safety and quality
assurance related issues
• Definition: This data point refers to the company's collaboration with
suppliers to address product safety and quality assurance related to issues
(a) Evidence of both supplier quality training and certification programs
(b) Evidence of supplier quality certifications programs
(c) Evidence of providing quality training to suppliers
(d) No evidence
• Keyword(s):
’quality’, ‘quality controls’, ‘quality assurance’, ‘training’, 'ISO 9001', 'TS
16949', 'ISO/TS 16949', 'certification', 'ISO certification'
- Scoring:
Evidence of both supplier quality training and certification

o
programs – Company trains contractors (including sub-
contractors if any) and suppliers on quality assurance on an
annual basis [or more frequently] and certifies its suppliers
to an internal certification standard or requires suppliers to
be certified to ISO 9001.
o Evidence of supplier quality certification programs –
Company certifies its contractors (including sub-
contractors if any) and suppliers to an internal certification
standard or requires suppliers to be certified to ISO 9001.
o Evidence of providing quality training to suppliers –
Company states that it trains contractors (including sub-
contractors if any) and suppliers on construction quality.
o No evidence – There is no evidence of training or
certification programs targeting product safety and
quality.
o Retail - Consumer Discretionary.
o For Food Retail, the certification we use is HACCP and/or
FSSC 22000. GFSI-benchmarked certifications should be
considered in providing credit.

Industry Guidelines

they were.
China A
o Scoring:
• Evidence of both supplier quality training and
certification programs – Search for key words:
▪ “ 行业联盟”/“ 生态联盟” Industry alliance /
ecological alliance
▪ “韧性伙伴” - resilient partnership
▪ Select this only when meeting all sub criteria

• Evidence of supplier quality certification programs
- Search for key words:
▪ “分级管理” – evaluate supplier by levels
Best practices：
▪
▪ Implementing transparent
procurement to build a responsible
supply chain
▪ Policy/Rules of supplier
classification & supplier list
management developed
▪ Policy/Rules of supplier certification
developed
▪ Regular evaluation on supplier
sourcing and quality levels
▪ Percentage of suppliers passing
quality, environment, and EHS
system certification disclosed
▪ No. of potential suppliers rejected
due to social responsibility non-
compliance disclosed
▪ No. of suppliers terminated
cooperation due to social
responsibility non-compliance
disclosed
• Evidence of providing quality training to suppliers -
Best practices:
▪ Holding regular tender and bidding meetings
and supplier meetings
▪ Developed an “industry partner” course
system, and disclose the number of project
managers from suppliers and number of
suppliers covered in training
- Sector: Consumer
o Whether the company requires suppliers to be certified to
ISO 9001 (including GB/T 19001—2016).
Regular audits of suppliers for their product safety and quality assurance
related issues
• Definition: This data point refers to the company's regular audit of
suppliers for their product safety and quality assurance related issues
(a) All or majority of critical suppliers audited by regulatory channels or by
company's compliance departments
(b) Selected critical suppliers are audited by regulatory bodies or company
compliance department
(c) General statements on supplier audits on their product safety and
quality assurances
(d) No evidence
• Keyword(s):
‘audit’, ‘certification’, ‘quality assurance’, ‘quality control’
- Scoring:
o All or majority of critical suppliers audited by regulatory
channels or by company's compliance departments –
There is evidence that all or majority of the company's main
contractors or suppliers are audited by government
regulatory bodies/authorities, or there is evidence that the
company has an internal compliance department that
audits all or majority of contractors and suppliers in terms
of construction, service, or product quality.
o Selected critical suppliers are audited by regulatory bodies
or company compliance department – There is evidence
that selected critical contractors or suppliers are audited by
government regulatory bodies/authorities, or there is
evidence that the company has an internal compliance
department that audits critical contractors and suppliers in
terms of construction, service, or product quality.
o General statements on supplier audits on their product
safety and quality assurances – Company states that it
audits contractors and suppliers on product safety and
quality.
o No evidence – There is no evidence of certifications or
internal audits conducted for its contractors, sub-
contractors, and suppliers.
Industry Guidelines

they were.
China A
Keywords: 供应商: suppliers, 审计，检查: audits
o “ 选用育留汰 ” – a contraction term of the supplier
management process for “screen, use, train, retain,
exclude”.
o Best practices:
• Rules of supplier performance evaluation developed
• Setting up a reward and punishment system, and
uses the three-dimensional (compliance, quality,
and EHS) dynamic monitoring mechanism to
manage and assess suppliers’ compliance level.
• Disclose the supplier category and number of
suppliers in each category
Existence of contingency plans or mitigation control systems

• Definition: These indicators assesses whether the company has systems
in place to mitigate risks that unexpected disruptions in manufacturing
operations or the supply chain will cause quality or safety problems and/or
production disruptions.
The indicator can relate to either 1) supply risk or 2) internal manufacturing

risk. The idea is that companies with mitigation/contingency plans are
better positioned to meet consumer demand in a quality manner, while
reducing the possibility of loss in operational efficiencies and financial
losses compared to companies with no contingency plans/mitigation
systems. Companies that have contingency plans to ensure that products
are in stock, reliable, and safe are better placed to minimize risks of
unexpected disruptions in supply of materials and minimize the risks of
encountering quality problems compared to companies with no such
systems.
1) Supply risk associated with company dependency on third party for

service/materials that are critical to ongoing flow of company operations.
Supply risk can be due to factors including financial instability, capability
to produce a good/service in a quality manner, or impact of natural
disasters.
2) Internal manufacturing risk is associated with the risk that companies'

own manufacturing capabilities may be affected by quality problems that
could compromise the quality and flow of goods or service to customers
and lead to unsafe and/or defective products/goods. Internal
manufacturing risk can be due to factors that may include (but are not
limited to) compromised quality control and quality assurance systems,
natural disasters, compromised sterility, or lapses in manufacturing
processes.
(a) Systematic risk mitigation process for all (e.g. dual sourcing, back-up
manufacturing sites)
(b) Mitigation systems in place for key products/ process/ components
only
(c) Some evidence of contingency plans but limited details on scope
(d) No evidence
• Keyword(s):
specific guidance.
- Scoring:
o Systematic risk mitigation process for all (e.g. dual
sourcing, back-up manufacturing sites) – The company
maintains comprehensive contingency plans to mitigate
risks that unexpected disruptions in its operations or supply
chain could lead to quality or safety issues procurement
policies and risk management practices, including
systematic risk mitigation processes such as [appropriate
use of dual or multiple suppliers / maintaining back-up
manufacturing sites].
o Mitigation systems in place for key products only – While
the company maintains risk mitigation systems to help
ensure that unexpected disruptions in its operations or
supply chain will lead to quality or safety problems, such as
[provide examples of supplier-or own manufacturing-related

systems], these processes are in place only for key
products.
o Some evidence of contingency plans but limited details on
scope – While we see evidence that the company maintains
o No evidence – We see no evidence that the company
maintains risk mitigation systems to help ensure that
unexpected disruptions in its operations or supply chain will
lead to quality or safety problems.

Industry Guidelines


they were.
China A
Keywords: 应急预案 : contingency plan
o contingency plans to ensure that products are in stock,
reliable, and safe
• maintained a supply base that are ready to reduce
dependency on third party for service/ materials
• maintained flexibility of its own Internal
manufacturing capabilities
• Participating in industry organizations to detect

potential sourcing, and promote industry
development
• Form an industry-university-research ecological
alliance to achieve technological self-reliance and
quality improvement
Measures and reports quantitative indicators related to service quality

performance or customer protection (e.g. clinical quality reports, customer
surveys)
• Definition: This data point refers to how the company measures and
reports quantitative indicators related to service quality performance or
customer protection
(a) Detailed, quantitative information on outcomes across all service
quality performance areas
(b) General / non-quant information on outcomes
(c) No evidence
• Keyword(s):
‘feedback’, ‘customer feedback’, ‘engagement’, ‘stakeholder engagement’,
‘survey’, ‘customer survey’
specific guidance.
- Scoring:
o Detailed, quantitative information on outcomes across all
service quality performance areas – Company discloses
quantitative results of customer feedback/satisfaction
surveys.
o General / non-quant information on outcomes – Company
releases general/broad statement on result of customer
feedback / satisfaction surveys.

Industry Guidelines
o Reason: Since Auto Components have lower exposure to end
customers.
China A
Keywords: 消费者调查：customer survey, 满意度：satisfaction rate, 消费
者投诉：customer complaints
o Scoring:
• Detailed, quantitative information on outcomes
across all service quality performance areas –
Key words: 满意度 – satisfaction rate
▪
Best
▪ Practices: satisfaction rates,
complaints, and details of areas to be
improved disclosed
• General / non-quant information on outcomes
▪ Disclose complaints handling rate by
residential/ commercial projects
▪ Disclose customer satisfaction rate by
residential/ commercial tenants
▪ No details of areas to be improved disclosed
Company’s complaints resolution mechanism to address its product and

service quality issues
• Definition: This data point refers to the company's complaints resolution
mechanism to address its products ad service quality issues
(a) Dedicated complaints resolution department and systematically seeks
post-market feedback from customers to improve quality
(b) Dedicated complaints resolution department
(c) General statements on having a complaints resolution mechanism (e.g.
call centers/hot line numbers/webforms, etc.)
(d) No evidence
• Keyword(s):
‘customer complaints’, ‘complaints resolution’, ‘helpline’, ‘customer
service’

specific guidance.
- Scoring:
o Dedicated complaints resolution department and
systematically seeks post-market feedback from
customers to improve quality – Company has a department
specializing on customer complaints and the company
states that it also has a formal customers survey
mechanism.
o Dedicated complaints resolution department – Company
has department specializing on customer complaints
resolution.
o General statements on having a complaints resolution
mechanism (e.g., call centers/hot line numbers/webforms,
etc.) – Company has a customer service department / hot
or chat line / website forms that allow customers to formally
submit complaints.
o No evidence – There is no evidence that the company has
a complaints resolution department or complaints
resolution mechanism.

Industry Guidelines

China A
Keywords: 消费者调查： customer survey, 消费者投诉： customer
complaints, 客服：customer service, 热线：hotline
o Scoring:
• Dedicated complaints resolution department and
systematically seeks post-market feedback from
customers to improve quality –
▪ Key words:
▪ 投诉 – complaints
▪ 意见反馈 – feedback
Clear standards and rules for customer
▪
complaint reporting and handling
▪ Disclose procedures to handle and improve
measures of customer complaints
• Dedicated complaints resolution department
▪ A special task force working on tracking the
progress of complaint resolution and repairs,
answer and proceed within a defined period
• General statements on having a complaints
resolution mechanism (e.g. call centers/hot line
numbers/webforms, etc.)
▪ Online channels, customer service hotline,
wechat miniprograms etc.
▪ No details of procedure described
Quality Management Certifications

List of quality management certifications
• Definition:
N/A - Long Text
• Keyword(s):
China A
o ISO 9001:2015 & China GB/T 19001-2015 Commented [LRA91]: Are these the only certifications
• ISO 9001: 2015 : specifies requirements for a quality to be considered here?
Kindly provide certifications for other industries
management system when an organization:
▪ needs to demonstrate its ability to
consistently provide products and services
that meet customer and applicable statutory
and regulatory requirements, and
▪ aims to enhance customer satisfaction
through the effective application of the
system, including processes for
improvement of the system and the
assurance of conformity to customer and
applicable statutory and regulatory

requirements.
▪ All the requirements of ISO 9001:2015 are
generic and are intended to be applicable to
any organization, regardless of its type or
size, or the products and services it provides.
o China standards “GB/T 19001-2015” or “GB/T 19001—
2015/ ISO 9001:2015” (enacted by China SAC , a member
body of the ISO) is the equivalent Chinese version of ISO
9001:2015. GB/T 19001-2015 includes all articles in the ISO
9000
o ISO/TS 9002 is the Guidelines for the application of ISO
9001:2015 .
Percentage of total R&D and Manufacturing sites certified

• Definition:
N/A – Numeric Value (Percentage)
• Keyword(s):
• General Procedure: Commented [LRA92]: Pending with Content Team
Commented [LRA93]: Pending with Content
Supply chain and sourcing

Membership in recognized industry-wide partnership(s) on supply
chain/contractor risk evaluation and mitigation
• Definition:
(a) Formal participant
(b) General commitment to industry or external standards but not a formal
participant
(c) Not Disclosed
• Keyword(s):
“Search the list of recognized supply chain initiatives below”
- Kindly refer to below partial list of recognized supply chain initiatives:
o Generic Industries
a. Association des Industries de Marque-Progress (AIM-
Progress)
b. Supplier Ethical Data Exchange (SEDEX)
c. Business Social Compliance Initiative (BSCI)
d. Initiative for Compliance and Sustainability (ICS)

o Automobiles
a. Automotive Industry Action Group (AIAG)
b. UN Global Compact (UNGC) Advisory Group on Supply
Chain Sustainability
c. CSR Europe Automotive Working Group on Supply Chain
Sustainability
o Healthcare Sector (Pharmaceuticals, Biotechnology,
Health Care Equipment, Life Sciences)
a. Rx-360 - Only those who commit to the "Rx 360
International Pharmaceutical Supply Chain Consortium"
get credit as "Formal participant"
o Aerospace & Defense
a. International Aerospace Quality Group (IAQG)

Industry Guidelines
o Sector / Industry: Auto Components and Real Estate
o Specific Guidance: Not to be scored



were.
o Sector: Retail - Consumer Discretionary, Food Products,

Restaurants, Retail - Food & Staples
▪ If companies require suppliers to adhere to the GFSI
benchmarked schemes (see list below), this is scored as
follows:
▪ If the company participates in one of the GFSI working groups
or sits on the board (Google the company name and site:
mygfsi.com to verify): Formal participant
▪ If the company is not on the board or in one the working groups:

General commitment to industry or external standards but not a
formal participant
safety requirements
• PrimusGFS
• IFS PACsecure
• GLOBALG.A.P.
• CanadaGAP
• SQF
o Sub-Industry: Real Estates

Conduct supplier training on quality assurance

Scope of supplier training
• Definition: This data point refers to the scope of supplier training
(a) All suppliers
(b) Most suppliers, or all 'high risk suppliers'
(c) Some suppliers
(d) Not disclosed
• Keyword(s):
‘training’, ‘contractor training’, ‘supplier training’, ‘quality assurance’,
‘supply chain training’, ‘quality control’, ‘quality controls’, ‘quality
management’, ‘capacity building’
- Scoring:
o All suppliers – The company trains all contractors, sub-
contractors, and suppliers on quality assurance,
demonstrating a proactive approach to promoting quality
management within the supply chain through supplier
capacity building. Note: Kindly please find explicit mention
of trainings that include all three groups: Contractors, Sub-

contractors, and Suppliers
o Most suppliers, or all 'high risk suppliers" – The company
trains [most contractors and suppliers or all high-risk
suppliers] on quality assurance, demonstrating a proactive
approach to promoting quality management within the
supply chain through contractor and supplier capacity
building.
o Some suppliers – The company trains [some/an unknown
percentage of/etc.] suppliers on quality assurance on an ad-
hoc or as needed basis only, suggesting a less proactive
approach to supplier capacity building compared to
companies that conduct such training for all suppliers or
those that are most at risk of encountering quality
problems. Additional guidance: Mentions ‘training’ only,
with no further details on scope.
o Not disclosed – There is no evidence that the company
trains suppliers on quality assurance, suggesting a relatively
weak approach to using training for ensuring quality
management at this stage of production compared to many
industry peers.
Industry Guidelines

were.
▪ For amusement park operators, please leave this as 'No Value'.

o Sub-Industry: Health Care Distributors

o Specific Guidance: Only if the company manufactures products of
its own brand Commented [LRA94]: Content Team to provide
example
o Sub-Industry: Life Sciences Tools & Services
o Specific Guidance: Check if applicable to the company Commented [LRA95]: Content Team to provide
example
o Sector: Retail - Consumer Discretionary, Food Products,
scored as "Most suppliers", unless if the company discloses that
it trains all suppliers.
safety requirements
• PrimusGFS
• IFS PACsecure
• GLOBALG.A.P.
• CanadaGAP
• SQF
▪ Align this with the frequency datapoint. If there is evidence on
frequency of supplier training but coverage is unclear, this
datapoint should be scored as "Some suppliers"
China A
- Best practices:
o Holding regular tender and bidding meetings and supplier
meetings
o Developed an “industry partner” course system, and
o disclose the number of project managers from suppliers
and number of suppliers covered in training
Frequency of supplier training

• Definition: This data point refers to the frequency of supplier training
(a) Annual training
(b) Periodic training but frequency is unknown
(c) Training is on an ad hoc as-needed basis only
(d) No evidence
• Keyword(s):
‘training’, ‘contractor training’, ‘supplier training’, ‘quality assurance’, ‘supply
chain training’, ‘quality control’, ‘quality controls’, ‘quality management’,
‘capacity building’
- Scoring:
o Annual Training – The company trains contractors,
subcontractors, and suppliers on quality assurance on an
annual basis [or more frequently], demonstrating a
proactive approach to promoting quality management
within the supply chain through supplier capacity building.
Note: Kindly please find explicit mention of trainings that
include all three groups: Contractors, Sub-contractors, and
Suppliers
o Periodic training but frequency is unknown – Though it
does not appear to conduct annual or more frequent
trainings for contractors and suppliers on quality assurance,
the company conducts periodic training, demonstrating a
relatively proactive approach to promoting quality
management within the supply chain through supplier
capacity building.
o Training is on an ad hoc as-needed basis only – The
company trains contractors and suppliers on quality
assurance on an ad-hoc or as needed basis only, suggesting
a less proactive approach to supplier capacity building
compared to companies that proactively conduct such
training on an annual or periodic basis. Additional guidance:
Mentions ‘training’ only, with no further details on scope.
contractors, subcontractors, and suppliers on quality
assurance, suggesting a relatively weak approach to using
training for ensuring quality management at this stage of
production compared to many industry peers.
o Retail - Consumer Discretionary

Industry Guidelines

o Specific Guidance: If there is evidence of supplier training but
frequency is unclear, this datapoint should be scored as "Training is
on an ad hoc as-needed basis only.

were.
▪ For amusement park operators, please leave this as 'No Value'

o Sub-Industry: Health Care Distributors

o Specific Guidance: Only if the company manufactures products of
its own brand
o Sub-Industry: Health Care Services

o Specific Guidance: Check if the company does any manufacturing
and assess accordingly

o Specific Guidance: Check if applicable to the company Commented [LRA96]: Content Team to provide
example
Certification program for suppliers

Tier 1 - Direct supplier facilities and processes certified by company
employees or third-party auditors Commented [LRA97]: Pending query with Content
• Definition: This data point refers to direct supplier facilities Team. Below query is available in Adhoc Teams
Channel.
(a) Yes [Vendor Query]
(b) No For any Healthcare Equipment industry, if there is no
evidence of GMP or supplier audits, can we still score
(c) Not Disclosed the mentioned data point as yes on the basis of ISO
• Keyword(s): 13485 certification?
‘certify’, ‘certification’, ‘audit’, ‘quality audit’, supplier assessment’ Commented [LRA98R97]: Still pending with Content
Additional key words: ‘direct suppliers’, ‘contractors’, ‘direct contractors’ Team
- Scoring:
oYes – if there is a certification policy for direct suppliers
including construction contractors.
Industry Guidelines

were.


to provide examples
o Sub-Industry: Health Care Equipment
o Default Scoring: Yes
o Sub-Industry: Health Care Services, Health Care Distributors

o Specific Guidance: Only applicable if the company does
manufacture
o Sub-Industry: Pharmaceuticals, Biotechnology

o Default Scoring: Yes
o Industry: Retail - Consumer Discretionary, Food Products,

scored as "Yes"
safety requirements
• PrimusGFS
• IFS PACsecure

• GLOBALG.A.P.
• CanadaGAP
• SQF
China A
o Best practices:
• All suppliers are certified by the Quality,
Environment and Occupational Health and Safety
Management Systems,
• regular evaluation program
• disclose the number fell under the unqualified
category in the most recent year
Tier 2 - Indirect / sub supplier facilities and processes certified by company

employees or third-party auditors
• Definition: This data point refers to indirect supplier facilities
(a) Yes
(b) No
(c) Not Disclosed
• Keyword(s):
‘certify’, ‘certification’, ‘audit’, ‘quality audit’, supplier assessment’
Additional key words: ‘sub-contractors’, ‘components suppliers’
- Scoring:
o Yes – if there is a certification policy for sub-contractors
working on construction sites and components (semi-
finished goods e.g. wood panels, hardware such as
doorknobs, nails used for construction) suppliers.
Industry Guidelines
o Sector: Health Care except Managed Health Care, Life Sciences

Tools & Services, Health Care Services, Health Care Distributors
o Specific Guidance: “Yes” only if company mentions that it audits ALL
its suppliers – rare


to provide examples
manufacture

o Specific Guidance: For amusement park operators, please leave this
as 'No Value'

o Default Scoring: not applicable, leave as No Value
China A
o Search word:“承包商” – sub contractor
Tier 3 - Ingredients / raw materials checked for quality on a regular basis Commented [LRA101]: Pending query with Content
• Definition: This data point refers to raw materials Team. Below query is available in Adhoc Teams
Channel.
(a) Yes [Vendor Query]
(b) No For any Healthcare Equipment industry, if there is no
evidence of GMP or supplier audits, can we still score
(c) Not Disclosed the mentioned data point as yes on the basis of ISO
• Keyword(s): 13485 certification?
‘certify’, ‘certification’, ‘audit’, ‘quality audit’, supplier assessment’, 'GMP' Commented [SAM102R101]: Unresolved; requires
Additional key words: ‘raw materials’, ‘materials’ response
• General Procedure: Commented [LRA103R101]: Still pending with
- Do not answer for Casinos & Gaming Content
- Scoring:
o Yes – if there is a certification policy to check quality of raw
materials (e.g., suppliers of timber, cement, rebar, etc.) provided
by suppliers.

Industry Guidelines
o Sector: Health Care except Managed Health Care, Life Sciences

Tools & Services, Health Care Services, Health Care Distributors
o Specific Guidance: “Yes” for Pharma companies if they audit at least
a portion of their raw material suppliers


to provide examples
manufacture

scored as "Yes"
safety requirements
• PrimusGFS
• IFS PACsecure
• GLOBALG.A.P.
• CanadaGAP
• SQF
Industry: Hotels & Travel

o
Specific Guidance:
o
were.
China A
o Keywords: “建材“ or “建筑材料” - construction materials“原
材料”- raw materials
General statement on supplier certification

• Definition: This data point refers to general statement on supplier
certification
(a) Yes
(b) No
(c) Not Disclosed
• Keyword(s):
‘certify’, ‘certification’, ‘audit’, ‘quality audit’, supplier assessment’
- Scoring:
o Please only score this indicator if none of the indicators
above (i.e., Tier 1, Tier 2, and Tier 3 data points) had been
scored with a "Yes". Otherwise, select "No Value"
o Yes – mentions contractor and/or supplier certification
only, with no further details provided.
Industry Guidelines

were.


to provide examples
manufacture

scored as "No value"
safety requirements
• PrimusGFS
• IFS PACsecure
• GLOBALG.A.P.
• CanadaGAP
• SQF
Responsible Marketing
China A
- So far, the Chinese government does not promulgate any regulatory
policies or laws pushing Chinese companies to establish responsible
market policy to advertise their products. However, the advertisement
law states that:
- advertisement on liquor shall not contain:
o any drinking inducement or instigation or immoderate
drinking;
o any description of an act of drinking;
o any description of driving a car, vessel, or airplane
driving, among others; or
o any explicit or implicit indication that drinking relieves

tension and anxiety, increases physical strength, or has
any other efficacy
- Please note these are not responsible marketing in case the company
states that they have the above policies, please do not give credit to
responsible marketing.
Evidence of policy on responsible marketing, advertising, and sales

• Definition: This data point refers to the company's evidence of policy on
responsible marketing, advertising, and sales
(a) Explicit policy articulated
(b) Evidence of commitment, but no policy articulated
(c) Not Disclosed
• Keyword(s):
'Responsible marketing', ‘responsible advertising’, 'commitment', 'company
values', 'mission', ‘consumer rights’, ‘customer protection’, ‘consumer
protection’ Additional key words: Please check antonyms such as
‘misleading’, ‘misleading information’, ‘false advertising’ as there may be a
company statement on this as well.
specific guidance.
- Scoring:
o Explicit policy articulated – Company has a clear
responsible marketing policy to protect the interests of
customers, citing consumer protections.
o Evidence of commitment, but no policy articulated –
Company has 'core values'/missions/integrity statement in
its website which includes a statement on providing quality
homes to its customers.
o Not disclosed – There is no evidence disclosed that the
company has a responsible marketing policy or statement.

Industry Guidelines
o Specific Guidance: only answer if issuer is China A
o Specific Guidance: Do not fill in

they were.

▪ Only score for companies generating more than 20% of
revenues from:
• candy/confectionery/sugary products/fatty foods
targeting children
• breast-milk substitutes
• alcoholic beverages
• tobacco
▪ Also score for drug retailers and check for responsible
dispensing policy for prescription drugs and controlled
substances (opioids, hallucinogens, depressants, etc.)

China A
Keywords: 负责任广告：responsible marketing, 理性饮酒：responsible
drinking, 理性赌博：responsible gambling
o Key words: 营销 – marketing and sales, CRM – customer
relation management
Best practices:
o
• Details of standardized marketing handbooks,
specifying risk control of contents, sales pitching
practices, and marketing tools.
- Sector: Consumer
o For HK listed casino & gambling issuers, if their operations
are in Macao, they are required to have responsible
gambling policies, based on the regulation of Casino
gambling operation, promulgated by Macao legislative

body 5724462a932ac998e7.pdf (al.gov.mo), article 42.
o Hence, suggest carefully looking the standalone policies
for responsible gambling.
Extent of employee training on responsible marketing and advertising

practices
• Definition: This data point refers to the extent to which employees train on
responsible marketing and advertising practices
(a) All employees are trained
(b) Only sales & marketing employees are trained
(c) Evidence of training but scope is unknown
(d) No evidence
• Keyword(s):
‘training’, ‘employee training’, ‘responsible marketing training’, ‘responsible
marketing training’
- Scoring:
o All employees are trained – Company states that all its
employees are trained on Responsible Marketing, i.e.
providing accurate data (such as accurate information on
the property being sold, transparency over terms and
conditions) to current and potential customers.
o Only sales & marketing employees are trained – Company
statement on training (as described above) is only
applicable for its Sales and Marketing staff.
o Evidence of training but scope is unknown – Company
provides brief statement that it trains its employees on
responsible marketing and/or the importance of providing
accurate and transparent information to customers.
o No evidence – There is no evidence disclosed that the
company has an employee training program for responsible
marketing.

Industry Guidelines



they were.
Sector: Health Care

o
Specific Guidance:
o
▪ If a company is a member company of IFPMA, can get minimal
credit: “Evidence of training but scope is unknown”
▪ If the company has IFPMA membership + policies, score higher:
“All employees are trained”
China A
o Scoring:
• All employees are trained – Only if explicitly stated
with details and samples provided
• Only sales & marketing employees are trained –
Product information training and evaluation for
marketing personnel, details of training content and
coverage disclosed
• Evidence of training but scope is unknown –
General statement.
Extent of audit and control procedures on responsible marketing

• Definition: This data point refers to the extent of audit and control
procedures on responsible marketing
(a) All operations
(b) Sales & marketing operations
(c) No evidence
• Keyword(s):
‘audit’ + ‘responsible marketing’. Additional key words: Please check

antonyms such as ‘misleading’, ‘misleading information’, ‘false advertising’
as there may be a company statement on this as well.
- Scoring:
o All operations – Company discloses that it regular performs
audits on its marketing schemes and practices.
o Sales & marketing operations – Company states that it
performs audits on practices of its Sales and Marketing
departments only.
o No evidence – There is no evidence that the company
performs audits of its marketing practices.
Industry Guidelines



they were.

▪ Most companies with responsible marketing policies are part of
national industry-wide alliances, such as the US and Canadian
Children’s Food and Beverage Advertising Initiative (CFBAI),
which specify criteria for advertising to children under 12
(reflected in the companies’ individual marketing policies). A lot
of companies are also part of the International Food and
Beverage Alliance (IFBA), which covers all countries which don’t
have a national alliance or pledge.
▪ Note that all these organizations audit their members on an

annual basis and publish reports of findings here (see bottom
of the page “Compliance and Monitoring” for all reports):
https://ifballiance.org/our-commitments/responsible-
marketing-advertising-to-children/. If a company is part of these
initiatives, you can select “systemic and regular audit systems”.
China A
o Scoring:
• All operations – Only if explicitly stated with details
and samples provided
• Sales & marketing operations – General statement
of marketing content inspections
Marketing, advertising & sales

Responsible marketing, advertising, and sales
• Definition: This data point refers to responsible marketing, advertising, and
sales
(a) Explicit policy articulated
(b) Evidence of commitment, but no policy articulated
(c) Not disclosed
• Keyword(s):
'Responsible marketing', ‘responsible advertising’, 'commitment', 'company
values', 'mission', ‘consumer rights’, ‘customer protection’, ‘consumer
protection’. Additional key words: Please check antonyms such as
‘misleading’, ‘misleading information’, ‘false advertising’ as there may be a
company statement on this as well.

o Keyword: responsible gaming policy
- Please check company website if they have a section on company
values and/or company mission. Please check ‘About us’ or company
information page as well.
- Scoring:
o Explicit policy articulated – Company has a clear
responsible marketing policy to protect the interests of
customers, which can also include reference to consumer

protections and/or consumer laws in their home market.
o Evidence of commitment, but no policy articulated –
Company has 'core values'/missions/integrity section in its
website which includes a statement on providing quality
homes to its customers.
o Not disclosed – There is no evidence disclosed that the
company has a responsible marketing policy or statement.

Industry Guidelines
scored as "No value"
safety requirements
• PrimusGFS
• IFS PACsecure
• GLOBALG.A.P.
• CanadaGAP
• SQF

▪ Only score for companies generating more than 20% of
revenues from:
• candy/confectionery/sugary products/fatty foods
targeting children
• breast-milk substitutes
• alcoholic beverages
• tobacco
▪ Also score for drug retailers and check for responsible

dispensing policy for prescription drugs and controlled
substances (opioids, hallucinogens, depressants, etc.)

were.
o Sector: Health Care except for Health Care Facilities, Health Care
Services, Managed Health Care, Life Sciences Tools & Services, and
SIC: 28341000 (Pharmaceutical preparations, research-stage) and
28362000 (Medical biological products, research-stage)
▪ If they are IFPMA member + have own separate code, get full
credit (Explicit policy articulated).
▪ Chinese Companies - If they have commitment to the regulation
+ have own separate code, get full credit (Explicit policy
articulated).
▪ If a company is a member company of IFPMA, they can get
“Evidence of commitment, but no policy articulated”.
▪ Chinese companies are required to follow the “Pharmaceutical
Administration Law of the People's Republic of China” and are
inspected by NMPA, so If a company has minimal disclosure, it
can get credit for “Evidence of commitment, but no policy
articulated”.
o Sub-Industry: Managed Health Care, Life Sciences Tools & Services,

Health Care Facilities, Health Care Services.
o SIC: 28341000 (Pharmaceutical preparations, research-stage) and
28362000 (Medical biological products, research-stage).
▪ To check for SIC in Data task, open SIC Exposure tab under
Categories. Check for SIC Description under SIC Exposure table.
China A
Keywords: 负责任广告：responsible marketing, 理性饮酒：responsible

drinking, 理性赌博：responsible gambling
o Key words: 营销 – marketing and sales, CRM – customer
relation management
Best practices:
o
• Details of standardized marketing handbooks,
specifying risk control of contents, sales pitching
practices, and marketing tools.
- Sector: Consumer
o For HK listed casino & gambling issuers, if their operations
are in Macao, they are required to have responsible
gambling policies, based on the regulation of Casino
gambling operation, promulgated by Macao legislative
body 5724462a932ac998e7.pdf (al.gov.mo), article 42.
o Hence, suggest carefully looking the standalone policies
for responsible gambling.
Trains employees on responsible marketing and advertising practices

• Definition: This data point seeks to know if the company trains its
employees on responsible marketing and advertising practices
(a) Demonstrates best practices of training in scope and depth
(b) Some evidence of training
(c) No evidence
• Keyword(s):
‘training’, ‘employee training’, ‘responsible marketing training’, ‘responsible
marketing training’
- Scoring:
o Demonstrates best practices of training in scope and depth
– Company trains its employees on consumer rights and
consumer legal protections, such as the relevant laws and
Consumer Protection Acts in its home market.
o Some evidence of training – Company provides brief
statement that it trains its employees on responsible
marketing but no details on programme scope.
o No evidence – There is no evidence disclosed that the
company has an employee training programme for
responsible marketing.

Industry Guidelines

o Default Scoring: Leave as No Value
o Sector: Health Care except for Health Care Facilities, Health Care
credit: “Some evidence of training”
▪ If the company has IFPMA membership + policies, score higher:
“Demonstrates best practices of training in scope and depth”


were.
China A
o Scoring:
• All employees are trained – Only if explicitly stated
with details and samples provided
• Only sales & marketing employees are trained –
Product information training and evaluation for
marketing personnel, details of training content and
coverage disclosed
• Evidence of training but scope is unknown –
General statement.
Audit/control procedures on responsible marketing

• Definition: This data point refers to the company's audit/ control
procedures on responsible marketing
(a) Systematic and regular audit systems
(b) Some evidence but not systematic (e.g. reactionary audits) or limited
detail regarding scope
(c) No evidence
• Keyword(s):
‘audit’ + ‘responsible marketing’
Additional key words: Please check antonyms such as ‘misleading’,
‘misleading information’, ‘false advertising’ as there may be a company
statement on this as well.
- Scoring:
o Systematic and regular audit systems – Company
discloses that it regularly performs audits on its marketing
schemes and practices, with details on frequency and
process disclosed as well.
o Some evidence but no systematic (e.g., Reactionary
audits) or limited detail regarding scope – Company states
that it performs audits on its marketing practices, but no
disclosure on schedule or details. Or company has
performed an audit after a customer complaint has been
filed or due to a controversy.
o No evidence – There is no evidence that the company
performs audits of its marketing practices.
Industry Guidelines

o Industry: Health Care except for Health Care Facilities, Health Care
credit: “Some evidence but no systematic (e.g., Reactionary
audits) or limited detail regarding scope”


were.
China A
o Scoring:
• All operations – Only if explicitly stated with details
and samples provided
• Sales & marketing operations – General statement
of marketing content inspections
Product Recalls
Product Recalls
• Definition: This data point refers to the company’s product recalls
• Keyword(s):
Recalls, recall, product recalls
- Input the product recalls of the company in the Recalls Database, which
lists the different sources for recalls
- Add details if available/applicable:
o Europe:
http://ec.europa.eu/consumers/safety/rapex/alerts/main/
index.cfm?event=main.listNotifications
o USA:
http://www-odi.nhtsa.dot.gov/owners/SearchSafetyIssues
https://www.fda.gov/safety/recalls-market-withdrawals-
safety-alerts
• UK
https://www.food.gov.uk/news-alerts/search/alerts

Industry Guidelines
- Sub-Industry: Casinos & Gaming
- Default Scoring: Leave as No Value
- Sector: Health Care except for Managed Health Care, Health Care
Facilities and SIC: 28341000 (Pharmaceutical preparations,
research-stage) and 28362000 (Medical biological products,
research-stage
o score for the following sub-industries: Health Care
Distributors and Health Care Services only.
o Do not score on sub-industries: Health Care Facilities and
Managed Health Care
o See additional section on scoring for Health Care
companies (healthcare and biotechnology)**
o Sub-Industry: Managed Health Care, Health Care Facilities


o Specific Guidelines: Examples of recall classes
▪ Class I Recall – Reasonable probability that use or exposure to
a product will cause serious, adverse health consequences.
Examples are:
1. Listeria Monocytogenes in dairy products
2. Undeclared peanuts or eggs in food item
▪ Class II Recall – Use or exposure to the product may cause
temporary or medically reversible adverse consequences, but
the probability of serious adverse health consequences is
remote. Examples are:
1. Wash water solution in fluid milk
2. Metal or glass fragments found in a product
▪ Class III Recall – Use or exposure to the product is not likely to
cause adverse health consequences. Examples are:
1. Misbranding of flavors (not using the term artificial)
2. Incorrect labeling type size and prominence

Value'
o Industry: Aerospace & Defense, Auto Components

o Specific Guidance: Recalls data is taken from controversies data.
Pls. confirm with Automobile’s lead/analysts for info on annual data
to be input on capture.
JP IMI
o Please double-check if there were any product recalls. It’s
recommended to run a keyword search (site:
https://www.xxx.co.jp “keyword”) within the company’s
website.
o Keywords: “リコール”, “回収”, “欠陥
o Source:
Regulations
Consumer Product Safety Act (消費生活用製品安全法)
o For pharmaceutical and medical equipment companies
• search company
names in a
highlighted box “
製造販売業者等名
称 ” at
Pharmaceutical and
Medical Devices
Agency’s website
(only in Japanese)
• https://www.info.pmda.go.jp/rsearch/html/menu_r
ecall_base.html
China A
Keywords: “退房”- refunded/withdraw housing purchase, “业主维权“
– buyer rights protection, “不满”– unsatisfied, 召回：recall,
下架：withdrawal, remove

o Include news coverage as source
- Sector: Consumer
o Google search: company name + recall
o 首页 (samr.gov.cn): in addition to public disclosure/news,
always refer to this website for double check the
companies’ violations in product safety; however, this is
only in Chinese.
o Kindly reach out to language analyst/market leads for help

if you look for some specific regulatory warnings and
payments to the company.
o After you type in companies’ Chinese names for search, it

will show all the regulatory letters (either warning or
penalties, or both) the company has got from local
regulatory body:
Regulatory Warnings
Regulatory Warnings
• Definition: This data point refers to company that have subject to Warning
Letters or Form 483.
• Keyword(s):
regulatory warning, warning letters, form 483a
- For Warning Letters, go to
https://www.fda.gov/ICECI/EnforcementActions/WarningLetters/
default.htm
- For Form 483s
o go to https://fdazilla.com/store/483s/
o Just type the name of the company and go down the list.
o You don't have to buy the actual report, just list the Form
483s which are "available" and go down the list to the
bottom of the page.
o The site lists first the Form 483s that are available for sale,
from newest to oldest, then lists the ones that are not
available for sale, for newest to oldest.
Industry Guidelines
- Sector: Health Care except for Managed Health Care, Health Care
Facilities and SIC: 28341000 (Pharmaceutical preparations, research-
stage) and 28362000 (Medical biological products, research-stage
o score for the following sub-industries: Health Care
Distributors, and Health Care Services only.
o Do not score on sub-industries: Health Care Facilities
Managed Health Care.
o See additional section on scoring for Health Care
companies (healthcare and biotechnology) **
o Sub-Industry: Managed Health Care, Health Care Facilities

China A
- Add Add associated controversies in regulatory warnings
o Google “issuer name” + “违规” (compliance violation) or “
违法” (legal violation)
o Key regulators: China MOHURD
Performance for Health Care companies (Pharmaceutics and Biotechnology)

The performance section is important for Pharma and Biotech companies, as these
industries are heavily regulated in terms of quality standards and commitments (e.g,
GMP quality standards), so company performance is a key differentiator.
We differentiate companies by regulatory warnings including:
• Formal ‘warning letters’
• Form 483s (warnings that could lead to an official warning letter, if not
addressed).
• Product recalls (Class I – most ‘severe’, Class II – moderate health risks; and
Class III -minor; these are classified as per regulatory agencies).
Capture scoring: in the Capture performance table, the term ‘regulatory warnings’ is
synonymous with ‘warning letters’. Only official ‘warning letters’ should be included
under ‘regulatory warnings’ heading, and only Forms 483 should be included under
‘Forms 483’ heading in Capture.
Additional guidance:
• If company’s revenue is exclusively derived from royalty or licensing fees and
does not produce/manufacture product itself (e.g., a one-time licensing fee
such as Arena) company needs to go to MC to propose override of company-
specific exposure score (size) to previous year level.
• Weighted Sum of Recalls – input data collected on recalls here (see process
below); this is auto-calculated. Even if there are zero recalls for the latest
year, make sure to insert/add the latest year as a row in Capture and just put
“0”– otherwise the calculations will not be accurate. Data should be captured
for the last three FY including the current one. E.g., if you are updating a
company in June FY 2022, you should include 2022 as the most recent year
and then also add 2021 and 2020 below.
• Structural – based on controversies, make sure to select “yes” or “no” –
should be based on the number of similar controversies faced by the
company during the previous years
• RECALLS AND WARNING LETTER GUIDANCE – PERFORMANCE section in
Capture: Many companies will manufacture a diverse range of products
including medical devices, pharma and biotech products so it is important to
check all relevant sources.
A. Counting recalls of subsidiaries: While counting recalls please ensure that
recalls of the subsidiaries are counted as well - usually all subsidiaries are
listed in the company's filings, try to capture information for as many

subsidiaries as recognized by the FDA/EPA because there might be
subsidiaries outside our coverage that have recalls which need to be
accounted as well
B. Newly acquired subsidiaries (attribute recalls initiated after the subsidiary
has been acquired) - parent is responsible for subsidiary’s recalls as well
after acquisition unless it is specifically stated as not being responsible
under the terms and conditions of the acquisition
C. Standardizing how we count a unique recall for medical devices/ supplies
(like what is provided for medicines)
• Warning letters info can be collected from:
o FDA: Imperative that search BOTH sites:
▪ http://www.fda.gov/Drugs/GuidanceComplianceRegulatoryIn
formation/EnforcementActivitiesbyFDA/WarningLettersandN
oticeofViolationLetterstoPharmaceuticalCompanies/ucm238
583.htm
▪ http://www.fda.gov/ICECI/EnforcementActions/WarningLette
rs/default.htm
o EMA (likely be called a ‘safety’ alert):
▪ http://www.ema.europa.eu/ema/index.jsp?curl=pages%2Fdo
cument_library%2Flanding%2Fdocument_library_search.jsp&
murl=menus%2Fdocument_library%2Fdocument_library.jsp&
mid=WC0b01ac058009a3dc&searchkwByEnter=true&isNewQ
uery=true&keyword=vertex&referenceNum=&docType=All&in
Year=All&committeeSelect=All&keywordSearch=Submit
o These databases are not always accurate or up to date. Doing
internet searches or in company disclosure (e.g., annual reports) may
sometimes also yield additional instances/information.
• Recalls info can be found at:
o Medical device recalls:
http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfRES/res.cfm
o Biologics:
http://www.fda.gov/BiologicsBloodVaccines/SafetyAvailability/Recal
ls/ucm245090.htm
o Drugs and everything else Database:
http://google2.fda.gov/search?client=FDAgov-
recalls&proxystylesheet=FDAgov-recalls&site=FDAgov-
recalls&filter=0&sort=date%3AD%3AS%3Ad1&getfields=*&requiredfie
lds=recall_category&q=Merck+%26+Co&btnG=Search
o Recall data in Capture should cover up to the date that you
cover/publish the company. In total, there should be at least three
years of recall data per company (3 most recent years), so depending
on what is already in Capture, you may need to research 1, 2, or 3
years of recall data. This means that if there is no recall data in
Capture, you may have to go back and collect three years of data so
that we can capture recall trends over time.
o NOTE: These databases are also not always accurate or up to date.
Doing internet searches or in company disclosure (e.g., annual
reports) may sometimes also yield additional instances/information.
o If there is no explicit classification of the recall (i.e. Class I, Class II,
Class III), use your judgment based on the Classification definitions
(found on the FDA website
http://www.fda.gov/Safety/Recalls/ucm165546.htm). HOWEVER, to
be classified as a Class I or Class II recall, there MUST be a direct
causal link between the product and the injury/death. Most
unclassified recalls will generally be captured as Class III.
Warranty Payments
• Definition: This data point refers to the warranty payments in USD millions.
• Keyword(s):
'provision', 'warrant', 'defect’
- Collected for Automobiles, Auto Components, and Aerospace &
Defense.
- Note on collecting warranty information: This is likely a line item in the
company accounts.
- To collect this efficiently, search company reports for the word warrant
(capturing instances of warranty and warranties). Provide source
locations and notes on any uncertainties (e.g., some companies may
sum warranties with other types of expenses and only discloses the
total, which would make it incomparable with companies that disclose
it as a separate line item).
- Warranty payments are also sometimes disclosed in terms of warranty
provisions. For such cases, take the amount of warranty provisions that
were spent or utilized for the fiscal year.
Industry-specific Performance Metrics Commented [LRA106]: Pending with Content
Other industry-specific metrics

• Definition:
• Keyword(s):
Customer Complaints Commented [LRA107]: Provide clear procedure.

• Definition: Refers to the customer complaints received by the company. 1. Should we add row even if no evidence found?
2. Should we enter zero if there's an explicit disclosure?
• Keyword(s): 3. What are we looking for this dp (i.e. all customer
complaints complaints or customer complaints related to quality
issue)
China A
o Add associated controversies in China A “Customer
Complaints”:
• Google: “issuer name” + “质量问题” (quality issue),
see if there are local news covering house buyers’
complaints.
Raw Material Sourcing

This issue evaluates the extent to which companies may face reputational risks by
sourcing or using raw materials with high environmental impacts. Scores are
based on reliance on environmentally intensive agricultural raw materials;
sustainable sourcing policies, commitments, and certification; and environmental
controversies in the supply chain.
- Industry: Retail - Consumer Discretionary

o The raw materials that are most commonly used are cotton,
leather, timber/paper, and palm oil (in cosmetics). While
these have all been deemed “environmentally impactful”
raw materials by the WWF, the impacts associated with
each are different:
• COTTON: one of the most pesticide-intensive crops
in the world
• LEATHER: methane production, deforestation
(especially in the Amazon), and intensive use of
chemicals in the dyeing and tanning process
• TIMBER/PAPER: deforestation
• PALM OIL: deforestation, carbon peatland burning
Note: Before answering the data points, check the ‘Estimated percent of sales
reliant on material (private label where applicable)’ and ‘Estimated percent of sales
from products typically containing material of concern’. Data points related to
materials with no value from these sections should be also scored as no value.

Industry Guideline
- Sector: Consumer Staples and Restaurants
o ‘Estimated percent of sales reliant on material (private label
where applicable)’ and ‘Estimated percent of sales from
products typically containing material of concern’ should be
updated by the Data team / vendor.
Exposure - Risk: Dependency on Raw Material Commented [LRA108]: To be checked if this will be
updated for Household & Personal Products
Estimated percent of sales reliant on material (private label where
applicable) Commented [LRA109]: Pending query with Content
• Definition: Indicates the estimated percent of sales reliant on material Team. Below query is available in Adhoc Teams
Channel.
(private label where applicable)
• Dropdown choices: Kindly confirm if this should be updated by the vendor
N/A – Numeric value in percentage and data ops.
• Keyword(s): Also, I have checked with the content analyst the excel
‘emission’ ‘energy’, ‘footprint’, ‘carbon’ file on which the content team maintains this data. But
as per the analyst, Ratings has stopped using the
estimates for private labels. Hence SIC-based
estimates - new estimates sheet was provided to me.
• Guidelines for Specific Industry / Market Appreciate if you can provide guidance on how to use
Industry Guideline this document. Or confirm if this should be updated by
- Sector: Consumer Staples and Restaurants the vendor/data ops.
o ‘Estimated percent of sales reliant on material (private label I also attached the file in our Teams channel, Exposure-
where applicable)’ and ‘Estimated percent of sales from Business segment data, and calculation.
products typically containing material of concern’ should be
https://onemsci.sharepoint.com/:x:/s/Ad-
updated by the Data team / vendor. hocdatarequests-O365-DataRatings-
o Please double check estimates by using the CS and Resto Queries/EX3_Sb9yvz5Bs_2KvTB1X2AB_GZUk0Gp2wLP
– RMS Estimates. Check SIC code tab to check existing sic 6L8khUei2w?e=qtivBR
codes and product breakdown. Example:
• If the company derives 50% of revenue from milk,
estimate for Beef/Dairy should be 50%.
• If the company derives 25% of revenue from fried

chips (ex. Lays, Cheetos), there is a possibility that
all these products are fried using oil containing palm
oil. Hence, palm oil estimate should be at 25%.
o In the event of multiple products, please add estimates.
Example:
• Fried chips accounted for 25% of revenue and 30%
was derived from biscuits containing palm oil-based
stabilizers, estimate for palm oil is 55%.
o In the absence of clear proxy data, please use the RMS
estimation sheet. Multiply the SIC code estimate with the
reported revenue derived per SIC code. Example:
• 5411-Grocery Stores accounted for 90% of the
company's revenue.
• RMS estimation sheet values are as follows:
▪ Beef/Dairy = 10%
▪ Seafood = 5%
▪ Palm oil = 30%
• Estimate for the company:
▪ Beef/Dairy = 90%*0.1 = 9%
▪ Seafood = 90%*0.05 = 4.5%
▪ Palm Oil = 90%*0.3 = 27%
Estimated percent of sales from products typically containing material of

concern Commented [LRA110]: Pending with China A Market
Sourcing Policy and Commitments - Policy to address

controversial raw materials
Publicly stated formal policy Company belongs to an industry group with a The company has a general
Raw
Data point stated policy statement of commitment but no
Material
formal policy
The company has its own policy or
commitment for environmental standard The company is using a third party’s
regarding the MSC (Marine Stewardship statement/policy/framework in its sourcing
Council); Aquaculture Stewardship (e.g., Sustainable Apparel Coalition commits to
Council (ASC); International Seafood reducing environmental impact of respective
Simply states that the following
Evidence of Sustainability Foundation (ISSF). raw material farming).
raw material is driving
commitments
Seafood environmental issues without
towards Sector: Consumer Staples/Restaurants Sector: Consumer Staples/Restaurants
defining a policy to respond to the
responsible* ▪ Company has a sustainable seafood ▪ Company commits to procuring sustainably
problem.
policy that explicitly bans the sale of certified seafood
threatened/endangered species ▪ Same procedure for Retail – Consumer
AND/OR specifies acceptable fishing Discretionary with significant involvement in
methods (e.g., pole-and-line) for food retailing (at least 20% of revenues).
seafood and specifies the chemical
inputs and antibiotics that can be used

for aquaculture
▪ Same procedure for Retail –
Consumer Discretionary with
significant involvement in food
retailing (at least 20% of revenues)
The company is using a third party’s
statement/policy/framework in its sourcing.
The company has its own policy or Industry: Household & Personal Products Simply states that the following
Paper commitment for environmental standard ▪ The products under consideration are tissue raw material is driving
and/or regarding the FSC (Forest Stewardship papers, diapers and sanitary napkins, we environmental issues without
Timber Council); Global Forest & Trade Network only look for FSC and GFTN and similar defining a policy to respond to the
(GFTN). commitments here, SAC is not considered, problem.
nor have we come across any issuer
mentioning this.

The company has its own policy or statement/policy/framework in its sourcing
commitment for environmental standard (e.g., Sustainable Apparel Coalition commits to
regarding the Roundtable for Sustainable reducing the environmental impact of
Palm Oil (RSPO) & UTZ CERTIFIED. respective raw material farming)
Sector: Consumer Staples/Restaurants Industry: Household & Personal Products

▪ Companies must have a formally ▪ We only check mention of RSPO here.
stated policy aligned with NDPE Simply states that the following
commitment (No deforestation, no Sector: Consumer Staples/Restaurants raw material is driving
Palm Oil peat, and no exploitation) ▪ Companies must be a member of RSPO and environmental issues without
must not have a formal palm oil policy. defining a policy to respond to the
Industry: Retail – Consumer problem.
Discretionary Industry: Retail – Consumer Discretionary
▪ Choose “publicly stated formal policy” ▪ Choose “company belongs to an industry
if the company has a no deforestation, group with a stated policy” if the company is
no peat, no exploitation policy a member of the Roundtable on Sustainable
Palm Oil (RSPO) and does not have its own
policy.

commitment for environmental standard
regarding the Global Roundtable for The company is using a third party’s
Sustainable Beef (forthcoming). statement/policy/framework in its sourcing
(e.g., Sustainable Apparel Coalition commits to
Sector: Consumer Staples/Restaurants reducing the environmental impact of
▪ Company has its own sustainable beef respective raw material farming)
policy/standard (this is extremely rare
Beef and/or raw material is driving
and is reserved for top companies Sector: Consumer Staples/Restaurants
dairy environmental issues without
only) or if the company has an explicit ▪ Company is a member of one or more of the
sourcing defining a policy to respond to the
policy to ban beef from the Amazon. following and does not have its own policy:
problem.
the Global Roundtable on Responsible Beef,
▪ Please note that sustainable the US Roundtable for Sustainable Beef, the
beef/dairy sourcing policy must have Canadian Roundtable for Sustainable Beef,
provisions on reducing environmental Brazilian Roundtable on Sustainable
impact (GHG emissions, methane) and Livestock
not solely focusing on animal welfare.
The company has its own policy or The company is using a third party’s
commitment for environmental standard statement/policy/framework in its sourcing
regarding the Leather Working Group (e.g., Sustainable Apparel Coalition commits to
(LWG BLC). reducing the environmental impact of
respective raw material farming)
Industry: Retail – Consumer
Leather environmental issues without
Discretionary Industry: Retail – Consumer Discretionary
defining a policy to respond to the
▪ Choose “publicly stated formal policy” ▪ Choose “company belongs to an industry
problem.
if the company’s policy addresses group with a stated policy” if the company is
both the origin of hides (i.e., a member of the Leather Working Group and
addressing deforestation) and tanning does not have its own policy
operations

statement/policy/framework in its sourcing
(e.g., Sustainable Apparel Coalition commits to
reducing the environmental impact of
respective raw material farming) Simply states that the following
commitment for environmental standard
Cotton Industry: Retail – Consumer Discretionary environmental issues without
regarding the Better Cotton Initiative
▪ If the company is a member of the Textile defining a policy to respond to the
(BCI); UTZ CERTIFIED.
Exchange or Better Cotton Initiative and problem.
does not have its own policy, choose
“company belongs to an industry group with
a stated policy”
*Leave at No Value if company is not dependent on seafood, paper, timber, palm oil, beef, dairy, leather, or cotton.
Sourcing Policy and Commitments - Percentage of products

externally certified by agencies
General Procedure or All Products More than 60% There is Some Between 30% Up to 30%
Data Point Raw Material Guidelines for Specific Evidence of and 60%
Industry / Market Certifications (approximately)
Sector: Consumer Evidence that all raw Evidence that General Evidence that a Evidence that
Staples/Restaurants materials sold or most or almost statement significant, yet some raw
External certification is used in products are all raw however, no minority of raw materials are
limited to externally certified materials are fact materials are certified
Seafood
Global Aquaculture externally supporting it certified (considering it
Alliance’s Best Aquaculture certified to be niche,
Practices (GAA BAP), MSC, therefore less
ASC than 30%)
Evidence that all raw Evidence that General Evidence that a Evidence that
materials sold or most or almost statement significant, yet some raw
used in products are all raw however, no minority of raw materials are
Paper and/or externally certified materials are fact materials are certified
Timber externally supporting it certified (considering it
certified to be niche,
therefore less
than 30%)
limited to RSPO externally certified materials are fact materials are certified
Extent of
certifications externally supporting it certified (considering it
certification*
Industry: Household & therefore less
Personal Products than 30%)
▪ We check for RSPO
commitment or mention
of using RSPO-certified
palm oil. Under this we
Palm Oil consider Book and Claim
and Mass balance level
certified palm oil (less
stringent of the 4 levels
under RSPO). If the
company is not a
member but mentions
sourcing palm oil from
certified supplier, we can
credit them of having
some evidence of
certification.
Beef and/or
limited to organic standards externally certified materials are fact materials are certified
dairy
externally supporting it certified (considering it
sourcing
therefore less
than 30%)
Industry: Textiles, Apparel Evidence that all raw Evidence that General Evidence that a Evidence that
& Luxury Goods and Retail materials sold or most or almost statement significant, yet some raw
– Consumer Discretionary used in products are all raw however, no minority of raw materials are
Leather Working Group externally certified materials are fact materials are certified
Leather
(LWG BLC) externally supporting it certified (considering it
certified to be niche, Commented [LRA111]: Pending with TALG and Retail
therefore less – CD industries
than 30%)
Evidence that all raw Evidence that General Evidence that a Evidence that
materials sold or most or almost statement significant, yet some raw
used in products are all raw however, no minority of raw materials are
externally certified materials are fact materials are certified
Cotton
externally supporting it certified (considering it
therefore less
than 30%)

externally certified by agencies with the most stringent
standards Commented [LRA112]: Pending with Retail – CD
content and research teams.
NOTE: Percentage of products externally certified by agencies with the most
stringent standards cannot be greater than ‘Percentage of products externally
certified by agencies’. It can be equal or less than ‘Percentage of products externally
certified by agencies’.
General Procedure or Guidelines for All Products More than There is Some Between 30% and Up to 30%
Data Point Raw Material Specific Industry / Market 60% Evidence of 60%
Certifications (approximately)
Evidence Evidence that
Evidence that
that most, or some raw
all raw
almost all Evidence that a materials are
materials sold General
raw significant, yet certified
or used in statements
Sector: Consumer Staples/Restaurants materials minority of raw (considering it
products are however, no fact
Seafood Stringent certification is limited to ASC and are materials are to be niche,
Extent of externally supporting it
MSC externally certified including therefore less
certification certified including a policy
certified a policy for than 30%
against the including a for partners
including a partners including a
most policy for
policy for policy for
stringent partners
partners partners)
criteria*
Industry: Retail – Consumer Discretionary Evidence that Evidence General Evidence that
Evidence that a
▪ We use the following to determine if all raw that most, or statements some raw
significant, yet
Paper and/or companies' products are indeed materials sold almost all however, no fact materials are
minority of raw
Timber externally certified with most stringent or used in raw supporting it certified
standards: products are materials including a policy
materials are
(considering it Commented [LRA113]: Pending with HPP industry.
certified including
▪ Forest Stewardship Council externally are for partners to be niche,
certified externally a policy for therefore less

Industry: Paper & Forest Products and including a certified partners than 30%
Containers & Packaging policy for including a including a
▪ Forest Stewardship Council (FSC) partners policy for policy for
▪ Global Forest & Trade Network (GFTN) partners partners)
▪ For FSC, note the difference between

FSC Chain of Custody certification and
FSC Forest Management certification.
▪ FSC CoC certification: If the company

states that x% of its supply chain is FSC-
certified, then we can give it credit for
that value
▪ FSC Forest Management certification: A

company manages its own forestlands
and says that 50% of its forests are FSC-
certified. 500 tons of its sourced pulp is
derived from its own forests, but it
sources a total of 1000 tons. The
calculation should be:
▪ % FSC certified = ((0.5*500)/1000)*100

So, in this case it should only be 25%.
Sector: Consumer Staples/Restaurants

▪ Stringent certification is limited to RSPO
identity preserved and segregated supply
chain only
Industry: Retail – Consumer Discretionary Evidence Evidence that

Evidence that
▪ We use the following to determine if that most, or some raw
all raw
companies' products are indeed almost all Evidence that a materials are
externally certified with most stringent raw significant, yet certified
standards: materials minority of raw (considering it
Palm Oil ▪ RSPO Identity Preserved, Segregated, are materials are to be niche,
externally supporting it
(please check the company’s RSPO externally certified including therefore less
certified including a policy
ACOP: certified a policy for than 30%
including a for partners
http://www.rspo.org/members/acop) including a partners including a
policy for
partners
Industry: Household & Personal Products partners partners)
▪ We consider Segregated and Identity
Preserved as the most stringent level of
RSPO credit. Also, this calculation is
accounted offline using RSPO data.
Commented [LRA114]: Content Team Pending -Will
Evidence Evidence that attach the spreadsheet in the chat. We can connect
Evidence that
all raw
that most, or some raw offline for details on how to score it
▪ At this point, there is only one (Rainforest almost all Evidence that a materials are
Alliance) and it has almost no uptake so raw significant, yet certified
choose “no value” for all companies materials minority of raw (considering it
Beef and/or dairy products are however, no fact
unless yours is one of the rare ones to are materials are to be niche,
sourcing externally supporting it
buy Rainforest Alliance-certified Beef. externally certified including therefore less
▪ Dairy-no identified standard yet, "no certified a policy for than 30%
value" for all companies. including a partners including a
policy for
partners
partners partners)
Evidence that
all raw
Industry: Retail – Consumer Discretionary almost all Evidence that a materials are
▪ We use the following to determine if raw significant, yet certified
companies' products are indeed materials minority of raw (considering it
Leather externally certified with most stringent are materials are to be niche,
standards: externally certified including therefore less
▪ Leather Working Group Gold certified a policy for than 30%
policy for
partners
partners partners)

Evidence that
all raw
Industry: Retail – Consumer Discretionary almost all Evidence that a materials are
▪ We use the following to determine if raw significant, yet certified
companies' products are indeed materials minority of raw (considering it
Cotton externally certified with most stringent are materials are to be niche,
standards: externally certified including therefore less
▪ Organic standards certified a policy for than 30%
policy for
partners
partners partners)
Sourcing Policy and Commitments - Future targets regarding

raw materials sourcing
General target of
General Procedure or continuous
The company has clear measurable targets or all products are
Data Point Raw Material Guidelines for Specific improvement (e.g.
already certified or traced
Industry / Market development of
tracking programs)
Targets are explicitly provided
Industry: Retail –
The General
Consumer Discretionary Sector: Consumer Staples/Restaurants
statement to show
▪ For companies with ▪ Targets are explicitly provided Company has made commitments to
their concern and an
significant involvement source MSC and ASC certified seafood (must be timebound and
Seafood indefinite vision to
in seafood and/or specific).
reduce the same is
beef/dairy, we follow ▪ Company bans the sale of threatened/endangered species AND/OR
highlighted without
guidance from specifies acceptable fishing methods (e.g., pole-and-line) for
any facts
Consumer Staples. seafood and specifies the chemical inputs and antibiotics that can
be used for aquaculture.
The General
statement to show
Industry: Retail – Consumer Discretionary
Paper and/or Timber indefinite vision to
▪ Choose “clear measurable targets” not only if the company has
reduce the same is
made commitments to source FSC and PEFC certified fiber, but
highlighted without
also if the company has targets to use recycled materials.
any facts

▪ Choose “clear measurable targets” if: -the company has made The General
Future targets* commitments to source RSPO certified palm oil (segregated and statement to show
identity preserved. their concern and an
Palm Oil ▪ If the company has targets to eliminate palm oil from its products. indefinite vision to
▪ It must be timebound and quantitative. reduce the same is
highlighted without
Industry: Retail – Consumer Discretionary any facts
made commitments to source RSPO certified palm oil, but also if
the company has targets to eliminate palm oil from its products.
Targets are explicitly provided The General
Consumer Discretionary
statement to show
For companies with
Sector: Consumer Staples/Restaurants their concern and an
Beef and/or dairy significant involvement in
▪ Choose “clear measurable targets” only if the company has made indefinite vision to
sourcing seafood and/or
commitments to source certified beef (including beef that meets reduce the same is
beef/dairy, we follow
their own company standard). This is extremely rare and most highlighted without
guidance from Consumer
companies will be “No targets”. any facts
Staples
Targets are explicitly provided The General
statement to show
Leather Industry: Retail – Consumer Discretionary their concern and an
▪ Choose “clear measurable targets” not only if the company has indefinite vision to
made commitments to source LWG certified leather, but also if the reduce the same is
company has targets to use less environmentally-impactful leather highlighted without

alternatives any facts
The General
statement to show
Cotton indefinite vision to
reduce the same is
made commitments to source BCI or organic-certified cotton, but
highlighted without
also if the company has targets to use recycled fabrics.
any facts

with traceable origin of raw materials
General Procedure or Guidelines for Specific Industry / All More than There is Some Between 30% and Up to 30%
Raw
Data Point Market Products 60% Evidence of 60%
Material
Certifications (approximately)
Sector: Consumer Staples/Restaurants Evidence Evidence that General Evidence that a Evidence that
▪ Companies with the following certifications can be that all raw most or statement significant, yet some raw
considered: materials almost all however, no fact minority of raw materials are
▪ MSC, ASC, GAA BAP, non-IUU (Illegal, Unreported, sold or rssaw supporting it materials are traceable
Unregulated), International Fishmeal and Fish Oil used in materials are traceable (considering it
Organization’s Responsible Supply Chain of Custody products traceable to be niche,
Seafood
(IFFO RS CoC) are therefore less
traceable than 30%)
Industry: Household & Personal Products
▪ Traceability is in usual cases linked with external
certification.
Industry: Paper & Forest Products and Containers & Evidence Evidence that General Evidence that a Evidence that
Packaging that all raw most or statement significant, yet some raw
▪ In addition to the certifications listed above, recycled materials almost all however, no fact minority of raw materials are
materials are also considered to be traceable. sold or raw supporting it materials are traceable
used in materials are traceable (considering it
Industry: Household & Personal Products products traceable to be niche,
Paper ▪ Traceability is in usual cases linked with external are therefore less
and/or certification. traceable than 30%)
Timber ▪ See % Chain of Custody (COC), and for Palm Oil, RSPO-
Segregated or Identity Preserved.
Percentage
of
▪ Use the following to determine if companies' products
traceability*
have traceable origin of raw materials.
▪ FSC and PEFC
Sector: Consumer Staples/Restaurants Evidence Evidence that General Evidence that a Evidence that
▪ Must be at the plantation level that all raw most or statement significant, yet some raw
Palm oil with RSPO identity preserved and segregated certs materials almost all however, no fact minority of raw materials are
can be considered for plantation traceability. sold or raw supporting it materials are traceable
used in materials are traceable (considering it
Industry: Retail – Consumer Discretionary products traceable to be niche,
▪ Use the following to determine if companies' products are therefore less
Palm Oil have traceable origin of raw materials. traceable than 30%)
▪ RSPO Identity Preserved, Segregated
Industry: Household & Personal Products

▪ Traceability is in usual cases linked with external
certification.
Evidence Evidence that General Evidence that a Evidence that

Beef Sector: Consumer Staples/Restaurants that all raw most or statement significant, yet some raw
and/or ▪ Must be at the plantation level materials almost all however, no fact minority of raw materials are
dairy sold or raw supporting it materials are traceable
sourcing Industry: Household & Personal Products used in materials are traceable (considering it
products traceable to be niche,
▪ Traceability is in usual cases linked with external are therefore less

certification. traceable than 30%)
Industry: Household & Personal Products Evidence Evidence that General Evidence that a Evidence that
▪ Traceability is in usual cases linked with external that all raw most or statement significant, yet some raw
certification. materials almost all however, no fact minority of raw materials are
sold or raw supporting it materials are traceable
Leather Industry: Retail – Consumer Discretionary used in materials are traceable (considering it
▪ Use the following to determine if companies' products products traceable to be niche,
have traceable origin of raw materials. are therefore less
▪ Any Leather Working Group level traceable than 30%)
Industry: Household & Personal Products Evidence Evidence that General Evidence that a Evidence that
▪ Traceability is in usual cases linked with external that all raw most or statement significant, yet some raw
certification. materials almost all however, no fact minority of raw materials are
sold or raw supporting it materials are traceable
Cotton
Industry: Retail – Consumer Discretionary used in materials are traceable (considering it
▪ Use the following to determine if companies' products products traceable to be niche,
have traceable origin of raw materials. are therefore less
▪ Organic and BCI standards traceable than 30%)
Certifications for the Listed Raw Materials

Summary of Percentage of products externally certified by agencies, Percentage of
products externally certified by agencies with the most stringent standards, and
Percentage of products with traceable origin of raw materials.
Seafood Paper and/or Timber Palm Oil Beef and/or dairy Leather Cotton
Data Point
sourcing
Roundtable for
Sustainable Palm Oil
(RSPO)
Sector: Consumer
Staples/Restaurants
Global Roundtable for
▪ Only RSPO identity
Sustainable Beef
preserved and
segregated.
Sector: Consumer
Staples/Restaurants
▪ At this point, there
Consumer Discretionary - Better Cotton
Forest Stewardship Council is only one
▪ We use the following to Initiative (BCI)
(FSC) (Rainforest
determine if companies' - Organic
Certification - Marine Alliance) and it has
products are indeed Standards
agencies Stewardship Council Industry: Paper & Forest almost no uptake
externally certified with Leather
with the (seafood) - Products and Containers & so choose “no
most stringent Working Group Industry: Retail
most Aquaculture Packaging value” for all
standards: (LWG BLC) – Consumer
stringent Stewardship Council ▪ Forest Stewardship Council companies unless
▪ RSPO Identity Discretionary
standards (aquaculture) (FSC) yours is one of the
Preserved, ▪ Organic
▪ Global Forest & Trade rare ones to buy
Segregated,). standards
Network (GFTN) Rainforest Alliance-
certified Beef.
Industry: Household &
▪ Dairy-no identified
Personal Products
standard yet, "no
▪ We consider
value" for all
Segregated and Identity
companies.
Preserved as the most
stringent level of RSPO
credit. Also, this
calculation is
accounted offline using
RSPO data.
- Programme for the

Endorsement of Forest
Certification (PEFC)
- Sustainable Forestry Initiative
(SFI)
Industry: Paper & Forest

Products and Containers &
Packaging
▪ Forest Stewardship Council - Organic
(FSC) - Roundtable on
▪ Global Forest & Trade Sustainable Biomaterials
- MSC Network (GFTN) (RSB)
- UTZ Certified
- ASC ▪ Canada Forest Accord
- Fairtrade
-GAA BAP Sustainable Forest Sector: Consumer Industry:
- non-IUU (Illegal, Management (CFA-SFM) Staples/Restaurants Retail –
Industry: Retail
Unreported, ▪ Programme for the ▪ All RSPO certificates Consumer
Other - Organic standards – Consumer
Unregulated) Endorsement of Forest Discretionary
certification Discretionary
- International Certification (PEFC) Industry: Retail – ▪ Leather
agencies ▪ Better
Fishmeal and Fish ▪ Sustainable Forestry Consumer Discretionary Working
Cotton
Oil Organization’s Initiative (SFI) ▪ RSPO Mass Balance, Group Silver
Initiative
Responsible Supply ▪ Forest-Trust and Book-and-Claim – and Bronze
(BCI)
Chain of Custody ▪ We also give credit for other also known as
(IFFO RS CoC) certifications, even if it's “GreenPalm” (please
local. Just verify the check the company’s
legitimacy of the certifying RSPO ACOP)
body by searching (common
in Canada)

Discretionary
▪ Programme for the
Endorsement of Forest
Certification (PEFC). Please
see list below.
- Global Aquaculture - Forest Stewardship Council

Alliance Best (FSC)
- Roundtable for
Aquaculture - Programme for the
Sustainable Palm Oil
Practices (GAA Endorsement of Forest
(RSPO)
BAP) Certification (PEFC)
- UTZ CERTIFIED Leather
- Good Agricultural - Better Cotton
- Rainforest Alliance (RA) Working Group
Practice Industry: Paper & Forest Initiative (BCI)
- Roundtable for Good Agricultural (LWG BLC)
(GlobalGAP) Products and Containers & - Organic
Sustainable Biofuel (RSB) Practice (GlobalGAP)
Packaging - UTZ
Sector: Consumer ▪ Forest Stewardship Council CERTIFIED
Sector: Consumer Sector: Consumer Industry:
Staples/Restaurants (FSC) - Fairtrade
Staples/Restaurants Staples/Restaurants Household &
▪ Companies with ▪ Global Forest & Trade
▪ Must be at the ▪ Must be at the Personal
the following Network (GFTN) Industry:
plantation level plantation level Products
certifications can ▪ Canada Forest Accord Household &
Palm oil with RSPO ▪ Traceability
be considered: Sustainable Forest Personal
identity preserved and Industry: Household is in usual
Certification ▪ MSC, ASC, Management (CFA-SFM) Products
segregated certs can be & Personal Products cases linked
includes GAA BAP, ▪ Programme for the ▪ Traceability
considered for plantation ▪ Traceability is in with
traceable non-IUU Endorsement of Forest is in usual
traceability. usual cases linked external
origin (Illegal, Certification (PEFC) cases linked
with external certification.
Unreported, ▪ For FSC, please note the with external
Industry: Retail – certification.
Unregulated), difference between FSC certification.
Consumer Discretionary Industry:
International Chain of Custody
▪ RSPO Identity Industry: Retail – Retail –
Fishmeal and certification and FSC Forest Industry: Retail
Preserved, Segregated Consumer Consumer
Fish Oil Management certification. – Consumer
Discretionary Discretionary
Organization’s See previous comment for Discretionary
▪ FSC and PEFC ▪ Any Leather
Responsible guidance. ▪ Organic and
Industry: Household & Working
Supply Chain ▪ For PEFC, please also note BCI
Personal Products Group level
of Custody the difference between the standards
▪ Traceability is in usual
(IFFO RS CoC) PEFC Chain of Custody
cases linked with
certification (PEFC ST 2002)
external certification.
Industry: Household and PEFC Sustainable Forest
& Personal Products Management (PEFC ST
▪ Traceability is in 1003)/PEFC Group Forest
usual cases Management Certification
linked with (PEFC ST 1002). See

external previous comment for
certification. guidance.
Industry: Household &

Personal Products
▪ Traceability is in usual cases
linked with external
certification.
▪ See % Chain of Custody
(COC), and for Palm Oil,
RSPO-Segregated or Identity
Preserved.

Discretionary
▪ Use the following to
determine if companies'
products have traceable
origin of raw materials.
FSC and PEFC
Programme for the Endorsement of Forest Certification (PEFC) for Retail

– Consumer Discretionary Paper and/or Timber Other Certification
agencies.
* Note that the following national certification agencies are part of PEFC:
• Australian Forestry • PEFC Luxembourg
• PEFC Austria • Malaysian Timber Certification Council (MTCC)
• PEFC Belgium • PEFC Netherlands
• Belarusian Association of Forest Certification • PEFC Norway
• Brazilian Forest Certification Programme (CERFLOR) • PEFC Poland
• PEFC Canada • PEFC Portugal
• Chile Forest Certification Corporation (CERTFOR) • PEFC Russia
• PEFC Czech Republic • Slovak Forest Certification Association
• PEFC Denmark • Institute for Forest Certification
• Estonian Forest Certification Council • PEFC Spain
• PEFC Finland • PEFC Sweden
• PEFC France • PEFC Switzerland
• PEFC Garbon • PEFC UK
• PEFC Germany • PEFC USA: American Tree Farm System (ATVS) and
• PEFC Italy • Sustainable Forestry Initiatives (SFI)
• PEFC Ireland • Sociedad de Productores Forestales del Uruguay
• PEFC Latvia
Sourcing Policy and Commitments - Collaboration with

suppliers to address impacts of raw materials
Collaboration Seafood Timber and/or paper Palm Oil Beef and/or dairy Leather Cotton
with
suppliers to
address
impacts of
raw
materials*
a. Requires all
suppliers to
a. Requires all
produce or
suppliers to produce or
a. Requires all suppliers purchase
purchase sustainable a. Requires all suppliers a. Requires all suppliers
to produce or purchase sustainable
seafood/aquaculture to produce or purchase to produce or purchase
sustainable palm oil and a. Requires all farmers
and verifies sustainable leather and sustainable leather and
timber/paper and verifies or suppliers to produce
compliance verifies compliance verifies compliance
verifies compliance compliance or purchase sustainable
b. In process of b. In process of b. In process of
b. In process of b. In process beef/dairy and verifies
implementing implementing land implementing land
implementing of compliance
sustainable management and management and
sustainable timber implementing b. In process of
seafood/aquaculture water/chemical water/chemical
purchasing sustainable implementing
production or reduction programs with reduction programs with
requirements at core palm oil sustainable beef/dairy
purchasing major leather suppliers major leather suppliers
suppliers purchasing production
requirements at core c. Has pilot projects on c. Has pilot projects on
c. Has pilot projects on requirements requirements with core
Dropdown suppliers EITHER land EITHER land
EITHER reducing at core farmers or suppliers
Options c. Has pilot projects on management for management for
environmental impact suppliers c. Has pilot projects on
EITHER reducing ranching OR ranching OR
of pulp processing OR c. Has pilot EITHER methane
chemical use in fish water/chemical water/chemical
purchasing timber from projects with reduction OR land
farming OR tracking management for leather management for leather
identified sustainable some management
origin to avoid tanning tanning
and legal sources suppliers to d. Educates farmers or
vulnerable ecosystems d. Educates suppliers on d. Educates suppliers on
d. Educates suppliers trace origin of suppliers on sustainable
d. Educates fisheries or responsible land responsible land
on responsible palm oil land management and
suppliers on management and/or management and/or
timber/paper sourcing d. Educates methane reduction
sustainable marine leather tanning leather tanning
and production suppliers on e. General Statement
resource management processes processes
e. General Statement responsible f. None
(or how to achieve e. General Statement e. General Statement
f. None palm oil
certification) f. None f. None
sourcing
e. General Statement
e. General
f. None
Statement
d. None
Sector: Consumer Industry: Paper & Sector: Consumer Industry: Retail –
Staples/Restaurants Forest Products and Staples/Restaurants Consumer Discretionary
▪ In process of Containers & ▪ In process of ▪ Choose “in process of
implementing Packaging implementing implementing water
Consumer Discretionary
sustainable ▪ Choose Requires all sustainable and pesticide
▪ Choose “all farmers or
beef/dairy suppliers if: beef/dairy production reduction programs
suppliers to produce
production ▪ If the company requirements with with major cotton
or purchase
requirements with outright states core farmers or suppliers” if the
sustainable leather
core farmers or that it verifies suppliers - Choose company participates
and verifies
suppliers - Choose if compliance only if the company in the Better Cotton
compliance” only if all
there is evidence (usually indicated has its own Initiative's Fast Track
Guidelines tanneries are certified
that the company in its supplier sustainable Programme or is
for Specific to the Leather Working
purchases MSC or code of conduct) beef/dairy standard involved in providing
Industry / Group Gold Level.
ASC certified ▪ If the company's ▪ Has pilot projects on technical assistance
Market ▪ Choose “all farmers or
seafood supply chain is EITHER methane to cotton farmers
suppliers to produce
▪ Educates farmers or 100% FSC- reduction OR land seeking organic
or purchase
suppliers on certified/company management - certification
sustainable leather
sustainable land has 100% FSC Choose if there is
and verifies
management and CoC certification evidence that the
compliance” only if all
methane reduction - ▪ If the company company is working
tanneries are certified
Choose if the sources all of its directly with ranchers
to the Leather Working
company is involved raw materials on these issues
Group Gold Level
in Fisheries from its own ▪ Educates farmers or
Improvement forests, AND the suppliers on
Projects (FIPs) company has sustainable land
100% certification management and

to the FSC Forest methane reduction -
Management Choose if there is
standard or the evidence that the
PEFC Sustainable company is working
Forest directly with dairy
Management farmers on these
(PEFC ST 1003) issues and/or
or the PEFC participating in
Group Forest industry-wide
Management projects run by
Certification national dairy
(PEFC ST 1002) initiatives (e.g.
or SFI Forest Innovation Center for
Management US Dairy, Dairy
certification Australia). Note that
not all companies
▪ Choose In process who are members of
of implementing if: these organizations
▪ If data point participate in their
"percentage of sustainability
products with programs
traceable origin of
raw materials" is
marked "all
products," tshis
should be the
minimum credit
given to the
company for this
data point
▪ If the company
has FSC
certification, but
not all of its
products are
certified to the
standard
- Read the options carefully and choose the best option that describe the company’s disclosure.
- Leave at No Value if company is not dependent on the mentioned raw material.
Industry: Household & Personal Productss

▪ Requires all suppliers: Company only sources raw materials from identified suppliers that carry a recognized third-party certification. The company may
also go into its supply chain and try to reduce their environmental impacts and introduce standards to its suppliers.
▪ In process of implementing sustainable purchasing requirements at core suppliers: Company has not yet achieved the goal of solely sourcing from
certified suppliers, but a large portion of its raw materials have traceable origin from sustainably certified suppliers.
▪ Has pilot projects: Some portions of its raw materials are sourced from sustainable suppliers, or the company is planning to extend the scope of
sustainable sourcing to more suppliers.
▪ Educates suppliers: Company requires its suppliers to source sustainably, but the scope remains unknown.
General statement: Company makes vague and inexplicit statement regarding suppliers’ engagement in sustainable raw material sourcing.
Practices
Below data points are tagged as China A hence only updated if the issuer is China A.
Commitments Cattle ranching: beef, Cotton Palm Oil Soy Timber and Paper
related to dairy, leather
sustainable
(a) Policy covers all (a) Commitment to (a) Commitment includes (a) Policy prohibits soy
(a) Commitment includes no
impact areas: source cotton certified sustainable palm oil from illegal sources,
sourcing of illegally harvested
Dropdown deforestation, GHG as organic (e.g., Textile sourcing, no deforestation, deforested areas, and
timber, not sourcing from
Options emissions from Exchange) and no peat disturbance requires suppliers to be
high-conservation value
livestock, traceability of (b) Commitment to (b) Commitment includes certified to a third-party
forests, and no clear-cutting
materials to farm level source sustainably sustainable palm oil standard
(b) Policy covers one or produced cotton (e.g., sourcing or the company is (b) Commitment to (b) Commitment includes at
two of the key impact Better Cotton) a member of the RSPO sourcing soy certified to least one of the provisions: no
areas: deforestation, (c) General (c) General commitment to a third-party standard sourcing of illegally harvested
GHG emissions from commitment to responsible sourcing of (c) No evidence of timber, not sourcing from
livestock, or traceability responsible sourcing materials commitments high-conservation value
of materials to farm (d) No evidence of (d) No evidence of forests, or no clear-cutting
level commitment commitments (c) General commitment to
(c) Policy provides a sourcing sustainably
general commitment to produced materials
minimizing (d) Minimum practices
environmental impact expected based on domestic
of beef, dairy or leather industry norms
production (e) No evidence of
commitment
Scoring - Answer if the company is a China A issuer.
Targets related Cattle ranching: beef, Cotton Palm Oil Soy Timber and Paper
to sourcing dairy, leather
sustainably
(a) The company has a
(a) The company has set
timebound target to (a) The company has set a
(a) The company has a a timebound
completely eliminate use of timebound commitment to
timebound target for commitment to use
palm oil in its goods use 100% certified or recycled
purchasing 100% 100% certified materials
(b) The company has a materials
sustainably produced (b) The company has
timebound target for (b) The company has
beef, dairy, or leather committed to 100% use
This data point is not purchasing 100% physically committed to 100% use of
Dropdown (b) The company has a of certified materials but
present in this raw traceable palm oil (Identity certified or recycled materials
Options target for purchasing timeframe is not
material. Preserved, Segregated) but timeframe is not specified
100% sustainably specified
(c) The company only has a (c) The company has a
produced beef, dairy, or (c) The company has a
timebound target for general commitment to
leather, but does not set general commitment to
purchasing 100% certified increase sourcing of
specific timeline increase sourcing of
palm oil, including Green sustainable timber and paper
(c) No targets sustainable soy
Palm certificates (d) No targets
(d) No targets"
(d) No targets
Traceability in Cattle ranching: beef, Cotton Palm Oil Soy Timber and Paper
the absence of dairy, leather
certification
(a) Evidence of palm
traceability to the fresh fruit
bunch level for the majority
of supply
(a) All soy is traceable to
(b) Evidence of palm
the source
This data point is not This data point is not traceability to the fresh fruit
Dropdown (b) Some soy is This data point is not present
present in this raw present in this raw bunch level for some
Options traceable to the source in this raw material.
material. material. supply
(c) No evidence of soy
(c) Evidence of palm oil
supply chain traceability
traceability to mill level
(d) No evidence of palm oil
supply chain traceability
beyond certification
Cattle ranching: beef, dairy, leather: Scope of programs to minimize GHG

emissions from livestock production, including animal feed mix and
manure management techniques
• Definition: Indicated if the extent of company’s programs to minimize GHG
emissions from livestock production, including animal feed mix and
manure management techniques
(a) GHG reduction measures implemented across all producers and
suppliers
(b) GHG reduction measures implemented at some operations
(c) GHG reduction measures are piloted at some farms
(d) No evidence of GHG emission reduction from livestock operations
• Keyword(s):
‘carbon’, ‘GHG’, ‘reduction’
- Leave at No Value if company is not dependent on cattle ranching: beef,
dairy, leather
China A
Cotton: Efforts to reduce environmental impact through supplier technical

assistance and capacity building
• Definition: Indicates the company’s effort to minimize/reduce
environmental impact through supplier technical assistance and capacity
building.
(a) Programs to reduce water and pesticide usage are implemented across
the entire supply chain
(b) Programs to reduce water and pesticide usage implemented at isolated
operations
(c) No evidence of direct supplier engagement efforts
• Keyword(s):
‘cotton’, ‘technical assistance’, ‘capacity building’
- Leave at No Value if company is not dependent on cotton.
China A
Performance
Below data points are tagged as China A hence only updated if the issuer is China A.
Responsible Cattle ranching: beef, Cotton Palm Oil Soy Timber and Paper
procurement of dairy, leather
products
(a) Evidence of (a) Evidence of
(a) Evidence of the
certification for all (a) Evidence of the certification for all
company sourcing
relevant materials company sourcing purchased soy (a) Evidence of certification
cotton certified as
linked to cattle ranching physically traceable palm (b) Evidence of for all timber and paper used
organic
(b) Evidence of oil (Identity Preserved, certification for a portion in goods
(b) Evidence of the
Dropdown certification for a Segregated) of soy purchased (b) Evidence of certification
company sourcing
Options portion of materials (b) Evidence of the (c) Evidence of suppliers for a portion of timber and
cotton with reduce
linked to cattle ranching company sourcing certified violating IBAMA paper used in goods
environmental impact
(c) No evidence of sustainable palm oil embargo/Soy (c) No evidence of
(Better Cotton)
certification for (c) No evidence of palm oil Moratorium certification
(c) No evidence of
materials linked to certification (d) No evidence of
cotton certification
cattle ranching certification
Evidence of Cattle ranching: beef, Cotton Palm Oil Soy Timber and Paper
using post- dairy, leather
industrial or
post-consumer
recycled
This data point is not (a) Yes This data point is not This data point is not (a) Yes
Dropdown
present on this raw (b) No present on this raw present on this raw (b) No
Options
material. (c) Not Disclosed material. material. (c) Not Disclosed
- Choose ‘Yes’ if there is an evidence of using post-industrial or post-consumer recycled (i.e. cotton or timber and paper)
Material Certification Commented [LRA115]: Pending with Content
Year Name of the Material Mass of materials Volume of materials Percentage of materials Details
Data Point
standard certified certified certified
Procedure
Responsible Investment
This issue evaluates the extent to which companies may face potential competitive
disadvantages in attracting ESG-related assets or asset depreciation due to ESG
investment risks. Scores are based on estimated portfolio exposure to ESG-related
risks; efforts to integrate ESG risks into investment and engagement decisions; and
controversial investments.
This key issue evaluates the extent of ESG integration that companies incorporate in
the management of their own investment portfolios (proprietary assets) or assets
under management (assets managed on behalf of clients). Companies that integrate
ESG risk analysis into their due diligence process across all investment portfolios
and asset classes and engage with investees on ESG issues score higher on this key
issue. Companies that are more exposed to potential ESG event risk and lack efforts
to conduct ESG due diligence score poorly on this key issue.
Sources:
• Annual Report/10K • Responsible Investment Policy
• ESG/Sustainability/CSR report • SASB Disclosure for Insurance
• Company Website Industry
• ESG Policy • Stewardship Report
• PRI Public Signatory Report • Website of Various Initiatives
• Proxy Voting Policy
Sources:
PRI Public Signatory Report, Stewardship Report, Proxy Voting Policy, Annual Report
Practices - ESG Integration in Investment Process

Percentage of total assets / assets under management covered by ESG
approach or theme (company-reported)
• Definition: Indicates the percent of assets or assets under management
that are covered by the company's ESG approach
• Keyword(s):
“AUM/Assets under management”, “Total assets”, “ESG
Integration/Incorporation” or “Responsible Investment” or “Sustainable
Finance”
- How much of the company’s total assets (including both proprietary
and third-party assets, if applicable) is covered by ESG?
- Use integration percentage numbers in PRI Transparency Report if

available
o Check Section OO 11: Asset class implementation gateway
indicators – information if they incorporate ESG in each
asset class that they have.
o If they incorporate ESG in all asset classes, do not enter
100% as we need to confirm the percentage.
o Percentage ratio for each asset class can be found in
Section LEI 01 (Listed Equity), Section FI 01 (Fixed Income),
Section PE 10 (Private Equity), and Section PR 07 (Real
Estate)
- If no PRI report, calculate the percentage by dividing amount of ESG
integrated assets by total assets. Only use the integration percentage
number disclosed by company when no other approaches available.
- Please be conservative when scoring this indicator - Don’t just put 100%
if company says “full integration” but we cannot verify (possibility of
greenwashing).
- When no disclosure is available, leave as “No Value” instead of 0%
- Provide internal notes especially if there is breakdown of AUM.
- Approach for different types of companies:
o Manages only proprietary assets (total assets = proprietary)
o Manages only third-party assets (total assets = third-party
AUM)
o Manages both proprietary and third-party assets (total
assets = sum of two). Need to make the judgment based on
company’s business segments.
• If the company has life insurance and asset
management business, check both the proprietary
investments and third-party investments.
• If the company has only asset management, double
check the nature of the company’s AUMs in their
disclosures (AR), as some asset management
companies have both proprietary and third-party
investments.
• Sources:
- PRI Public Signatory Report, ESG/Sustainability/CSR report, Company
website, Annual Report
Policies and procedures to integrate ESG considerations

• Definition: Indicates if company has policies and procedures to integrate
ESG considerations
(a) Yes - discloses ESG policies
(b) Yes - discloses governance policies only
(c) No
• Keyword(s):
'ESG', ‘Environmental risk’, ‘Governance Policy/Criteria’
- These are ESG policies pertaining to investment decisions of a
committee. A mere statement that the company incorporates ESG
factors is not sufficient to score this datapoint.
- Sources:
o ESG/Sustainability/CSR report, Responsible Investment Policy,
Annual Report
- Scoring
o Yes - discloses ESG policies - Details or examples of ESG
policies disclosed – not sufficient to simply state that ESG
issues are incorporated. The company has a standalone policy
for ESG investing and discloses about the body/team
overlooking this task and has an exclusion list, screening
criteria, inclusion themes/industries.
o Yes - discloses governance policies only
▪ Details of governance policies provided but no
evidence of environmental or social policies. The
company has a general statement for incorporating
ESG indicators in initial screening.
▪ The governance policies here refer to whether the
company requires investee to meet certain
governance threshold (board independence, board
diversity, ownership structure, etc.) or only
considers governance ratings of investee, not the
proxy policy of the company itself (which is scored
in the engagement indicators).

- Industry/ Sub-Industry: Mortgage REITs
- General Procedure: For Internally managed mREITs, do not select
Yes - discloses governance policies only
Dedicated staff responsible for analyzing ESG issues or trains financial

analysts on ESG issues
• Definition: Indicates if the company has dedicated staff responsible for
analyzing ESG issues or trains financial analysts on ESG issues
(a) Yes
(b) No dedicated staff - but trains financial analysts on ESG issues
(c) No
• Keyword(s):
'ESG', 'Responsible Investment', 'Sustainable Investment', 'Training'
- Who analyzes the ESG issues?
- Give credit if the company has
o sustainability committee overlooking in the whole process
OR
o specific staff being trained on ESG factors issues.
- Training on ESG issues must be part of analyst core training. Example:
training on ESG analysis. Training on company’s CSR strategy should
not be taken into consideration.
- We are looking at company’s investment process before investing in
certain asset classes or companies – whether the company has
specific personnel looking at ESG factors when making investment
decisions.
Practices – Company is participant or signatory to:

**Always refer directly in the websites. The company should be a signatory or
participant to have a score in these data points.
Signatory to the Principles for Responsible Investment (PRI)

• Definition:
- Indicates if the company is a signatory to the UN Principles for
Responsible Investment (PRI)
- Check for UN PRI website for additional information
(a) Yes
(b) No
(c) Not Disclosed
• Keyword(s):
'United Nation', 'UN', 'PRI', 'Responsible Investment'
- Check if the company is an UN PRI Signatory by checking UN PRI

website. AR/CSR of the company can also be checked.
Signatory or participant at the Investor Network on Climate Risk (INCR)

• Definition:
- Indicates if the company is a signatory or participant at the Investor
Network on Climate Risk (INCR)
- Check for INCR or CERES website for additional information
• Keyword(s):
'INCR', 'Climate', 'Investor Network'
(a) Yes
(b) No
(c) Not Disclosed
- Check if the company is an Investor Network on Climate Risk (INCR)
Signatory in INCR or CERES website. AR/CSR of the company can also
be checked.
Signatory or participant at the Institutional Investors Group on Climate

Change (IIGCC)
• Definition:
- Indicates if the company is a signatory or participant at the
Institutional Investors Group on Climate Change (IIGCC)
- Check for IIGCC website for additional information
• Keyword(s):
'IIGCC', 'Climate Change'
(a) Yes
(b) No
(c) Not Disclosed
- Check if the company is an Institutional Investor Group on Climate
Change (IIGCC) in IIGCC Website. AR/CSR of the company can also be
checked.
Signatory or participant at the Investor Group on Climate Change (IGCC)

• Definition:
- Indicates if the company is a signatory or participant at the
Investors Group on Climate Change (IGCC)
• Keyword(s):
'IGCC', 'Climate Change'
(a) Yes
(b) No
(c) Not Disclosed
- Check if the company is an Investor Group on Climate Change (IGCC)
in IGCC or AIGCC website.
- AR/CSR of the company can also be checked.
Signatory or participant at Social Investment Forum (SIF)

• Definition:
- Indicates if the company is a signatory or participant at Social
Investment Forum (SIF)
- Check for SIF websites
• Keyword(s):
‘SIF’, ‘social’, ‘responsible’
(a) Yes
(b) No
(c) Not Disclosed
- Check the responsible investment section of ESG report/CSR report
first. Search for “social”, “responsible”.
- Check if the company is a signatory or participant at Social
Investment Forum (SIF) using the links below
Location SIF Name Link

Responsible Investment Association Australasia
Australia (RIAA) RIAA - Members
Denmark DANSIF DANSIF - Members
Europe EuroSIF EuroSIF Network
Ireland SIF Ireland SIF Ireland - Partners
Italy Forum per la Finanza Sostenibile Members
SpainSIF- Associate
Spain spainSIF Members
Switzerland Swiss Sustainable Finance (SSF) SSF - Members
UK UKSIF UKSIF - Members
Finland FinSIF FinSIF - Members
France Forum pour l'Investissement Responsable(FIR) FIR - Members
Korea Korean Sustainability Investing Forum (KoSIF) KoSIF - Networks
Norweigian Forum for Sustainable and Responsible

Norway Investment (NorSIF) NorSIF - Members
Sweden SWESIF SWESIF - Members
United
States USSIF USSIF - Members
Signatory or participant at a responsible investing initiative

• Definition:
- Indicates the responsible investing initiative other than PRI, INCR,
IIGCC, IGCC and SIF on which the company is a signatory or
participant.
• Keyword(s):
(a) Yes
(b) No
(c) Not Disclosed
- This indicator is ‘other’ category, meaning the issuer is signatory or
participant at a responsible investing initiative other than PRI, INCR,
IIGCC, IGCC and SIF.
- Please make sure that the initiative is related to responsible investing.
- Any organization that promotes integrating ESG considerations in
investment. Check the Responsible Investment section of ESG
report/CSR for any mention of these initiatives.
- Please name of the other initiatives here and provide details in the
next indicator “Other details”.
Other Details
• Definition:
- Indicates the responsible investing initiative other than PRI, INCR,
IIGCC, IGCC and SIF on which the company is a signatory or
participant.
• Keyword(s):
N/A – Short Text
General Procedure:
- Any organization that promotes integrating ESG considerations in
investment. Check the Responsible Investment section of ESG
report/CSR for any mention of these initiatives. Please provide
details here.
- Interlinked with Signatory or participant at a responsible investing

initiative.
o If Signatory or participant at a responsible investing
initiative is Yes, provide the name of responsible investing
initiative in this field.
Practices – Asset Mix (Estimated)

▪ Listed Equity
▪ Listed Equity - Emerging Markets
▪ Fixed Income - Non-Corporate or Unknown
▪ Fixed Income - Corporate
▪ Private Equity
▪ Real Estate
▪ Hedge Funds / Alternative Investments
▪ Other and Other Details
N/A – Numeric Value (in percentage) except Other Details (i.e., short text)
- Asset mix is the mix of investment assets of Asset Management
Companies. The breakdown needed is from Assets Under
Management (AUM).
- Update categories where disclosures are available. Leave Blank if
no disclosures found. Do not enter zero in these fields.
- Listed Equity vs Listed Equity - Emerging Markets:
o We base this on the location of the company. Check MSCI
Markets to know whether the country is categorized in
developed or emerging market.
o When no distinction is made between developed and
emerging market equities, enter the figure for equities into
the Listed Equity field.
- Fixed Income - Non-Corporate or Unknown vs Fixed Income –
Corporate:
o When no distinction is made between corporate and non-
corporate bonds, enter figure in Fixed Income - Non-
Corporate or Unknown
o Sovereign bonds – enter this in Fixed Income - Non-
Corporate or Unknown
- Alternative Investments
o Commodities, structured products, etc.
o Sometimes companies tag this as alternatives in general
- Other and Other Details: Other assets not categorized will be

entered in ‘Other’ field and provide additional information in ‘Other
Details’
- Can also be found in company/investor presentation
Practices – ESG factors incorporated into investment

processes across the following asset classes:
- If asset mix data points are updated, below data points should be
aligned.
For example, the company do not have real estate
▪
investment (i.e., real estate field is blank) then, Extent of
ESG factors integration into real estate investment process
should be “No value”.
• Note that this should be ‘No Value’ to avoid
confusion and won’t affect the final rating.
- If asset mix is not available, check the disclosures and try to look
for evidence where the company is investing (i.e., they invest in
bonds, equities, real estate, etc.)
▪ Extent of ESG factors integration into listed equity investment process
▪ Extent of ESG factors integration into emerging markets listed equity
investment process
▪ Extent of ESG factors integration into fixed income (non-corporate)
investment process
▪ Extent of ESG factors integration into fixed income (corporate) investment
process
▪ Extent of ESG factors integration into private equity investment process
▪ Extent of ESG factors integration into real estate investment process
▪ Extent of ESG factors integration into hedge funds and alternative
investments
(a) Company-wide integration
(b) Partial integration or integration for specific funds
(c) Governance only ESG integration
(d) Where relevant or part of regular business integration of ESG with no
evidence of commitment or method
(e) No evidence
- For these data points, check if the company has mentioned about ESG
investments. Check their asset under management which gives a
picture of how their investments are spread. For example, Fixed
Income, Corporate Bonds, Equity etc. If the company has PRI report,
refer to the integration percentages in the report.
- Sources:
o PRI Public Signatory Report, ESG/Sustainability/CSR report,
Annual Report
- If UNPRI Report is available, check OO 11 section to score this data
point.
- Scoring:
o ‘Company-wide integration’: ESG is incorporated into the
management of this asset class throughout the company’s
own operations or external mandates. This can only be given if
there is explicit evidence that 100% of its assets (both
proprietary and third-party assets) classified under the asset
class is covered by ESG due diligence policies.
o ‘Partial integration or integration for specific funds’: There is
evidence that ESG is incorporated into the management of this
asset type, but not that this takes places for all assets, whether
managed internally or externally; or company is in the process
of rolling out ESG integration for that particular asset class.
o ‘Governance only ESG integration’:
• Governance issues are incorporated but no evidence of
environmental or social issues.
• If they assess the governance structure of their
investee companies, then choose this option.
• This is more on private equity investments since the
company is directly involved in the management of its
investee companies. Sometimes their criteria are on
the governance aspects only requiring certain aspects
to be in line to a good governance structure.
o ‘Where relevant or part of regular business integration of ESG
with no evidence of commitment or method’:
• The company states that ESG is incorporated but gives
no details of how this takes place. Generic disclosures
that they do ESG integration into their investment, but
we do not know the extent of how much they
incorporate in their investment.
- Note: For an asset class to score better than ‘Where relevant or part of
regular business integration of ESG with no evidence of commitment
or method’, there must be evidence that ESG is incorporated into the
management of that asset class specifically. This is common for
equities and real estate, but less for fixed income or alternatives.

o Generally, we only score the ESG factors integration into
real estate investment process.
o Unless there is evidence of investing in other relevant
asset classes (for which we have options to score), we
score all the other as no value.
o If there is evidence of investing in other asset classes, we
score it for this asset class (in such cases, no evidence of
a policy for the relevant asset class would result in no
evidence instead of no value).
Practices – Company Engagement

- This section indicates how the company engages with its investee
companies.
- We are looking for the proxy voting policy of the company for its
investments. This is not related to the company’s proxy voting
policy for its own management or business.
Disclosure of engagement or proxy voting policy

• Definition:
- Indicates the existence of corporate engagement programs or
proxy voting policy on portfolio and/or investment management
- Examples: Banks often have proxy policies that govern how they
can vote or engage with companies and on what issues.
- If Engagement or proxy voting policy address environmental, social
and governance issues is yes, often, this is also a Yes. But make
sure that you’re able to find evidence of both.
(a) Yes
(b) No
(c) Not Applicable
• Keyword(s):
‘proxy policy', 'company engagement' or 'proxy voting'
- We are looking for engagement or proxy voting policy. If we find
evidence that the company is engaging directly with their investees
then, give credit. Note that we also need to find details of its
engagement criteria (such as which issues they would advise

clients to vote on).
- Policy must be publicly disclosed in reporting or on website to score
‘Yes’ or substantive details about the engagement approach are
discussed in company disclosure.
- Details may be included on a separate website for the asset
management arm, where this exists.
- If the company is a signatory to UNPRI, then this indicator can be
scored based on available information in Transparency report that
can be accessed from UNPRI website. But we should rely on
company website first. In most cases, company will first disclose
on their own website, then file transparency report to UNPRI.

o Although traditional mREITs do not in equities and therefore
cannot engage or do proxy voting in the traditional sense
(from shareholder with voting rights point of view), they can
still engage with the relevant stakeholders in their
investments. The most common example would be
originators of the mortgage loans they purchase
o However, given the limitations for engagement (and
absence of proxy voting rights), we can give credit for
evidence of doing engagement activities with stakeholders
in their investments (like in the below example), even if it is
not a formulated policy.
JP IMI
- Industry/ Sub-Industry: All
- Scoring: Yes - if company adopts JP Stewardship Code
- Source:
https://www.fsa.go.jp/en/refer/councils/stewardship/20200324/0
1.pdf
Engagement or proxy voting policy address environmental, social and

governance issues
• Definition:
- Indicates if the company has engagement or proxy voting policy
address environmental, social and governance issues.
- Records if the company votes on behalf of its clients for the
responsible investment.
(a) Yes
(b) No
(c) Not Applicable
• Keyword(s):
‘proxy policy', 'company engagement' or 'proxy voting'
- Same approach as previous data point (i.e., Disclosure of

engagement or proxy voting policy) but for this data point we need
to check if the company addresses ESG issues.
- Details of ESG issues must be given to score ‘Yes’ but policy does
not have to cover all 3 categories of ESG.
- If the company is a signatory to UNPRI, then this indicator can be
scored based on available information in Transparency report that
can be accessed from UNPRI website. But we should rely on
company website first. In most cases, company will first disclose
on their own website, then file transparency report to UNPRI.

o Same as Disclosure of engagement or proxy voting policy,
if they claim engagement, we look to find whether they
engage on ESG- and sustainability-related issues.
Dedicated staff responsible for analyzing ESG issues and monitoring ESG
engagement policies
• Definition: Indicates the company’s dedicated staff responsible for
analyzing ESG issues and monitoring ESG engagement policies
(a) Yes
(b) No
(c) Not Applicable
- Individual or team responsible for looking at ESG factors related to
their investee companies (post-investment monitoring).
- If there’s an engagement team/person and they engage with
investees on ESG issues, we can give credit.
- The scope of ESG issues covered is not considered here.
- If the company only mentions ESG team/committee, we cannot
give the company credit. This should only be given credit when
there’s a separate engagement/proxy voting team and they monitor
ESG performance of investees.

o Same as Disclosure of engagement or proxy voting policy,

if they claim engagement, we’d want them to have
dedicated staff.
Exposure – ESG Risk Assessment by Geography

Assets under management by geography
• Definition:
- Indicates the % of Assets Under Management in High-, Med-, or
Low-Risk Geographies based on depletion of natural resources,
impacts of climate change, access to skilled labor, health and
education levels, corruption, and governance effectiveness.
- Do not update data points under this section.
Assets under management by asset class (%)

• Definition:
- Indicates the % of Assets Under Management in High-, Med-, or
Low-Risk Asset Classes based on liquidity, volatility, and
transaction costs, which could heighten materiality of underlying
ESG factors.
- Do not update data points under this section.
Supply Chain Labor Standards

This issue evaluates the extent to which companies may face reputational risks or
production disruptions due to substandard treatment of workers in the company’s
supply chain. Scores are based on brand visibility and reliance on outsourced
production; labor policies, compliance monitoring, and engagement with suppliers;
and labor controversies in the supply chain.
Sources: Company Website show their supplier or locations, Website of the

Membership on Organization/Association
Exposure – Additional Exposure Indicator Commented [LRA116]: Pending with Market Expert to
provide clear guidance
Estimated percentage of revenue from products for which production is
outsourced to developing and frontier markets
• Definition: Indicates the percentage of revenue from products for which
production is outsourced to developing and frontier markets.
N/A – Numeric value in percentage
• Keyword(s):
- For Consumer Staples:
o check if the company have Private Label Products also the
dependency on developing countries and % of revenue
derived in Private Label Products.
China A
Exposure – Trigger
Company is on Interbrand's Top 100 Brands list.
• Definition: Indicates if the company is on Interbrand's Top 100 Brands list.
(a) Yes
(b) No
(c) Not Disclosed
• Keyword(s):
‘interbrand’
- Go to Interbrand’s website and search for the issuer.
- For Restaurants:
oThere is some company have brands or franchisee which

may not have the same name with the Master Franchisee.
In those cases, this can be still considered.
• Examples: McDonalds in Latin America – Arcos
Dorados Holdings (Master Franchisee)
- For Consumer Staples:
o check if the company have Private Label Products also the
dependency on developing countries and % of revenue
derived in Private Label Products.
Exposure – Footprint
Private label as percentage of sales (est.)
• Definition: Indicates the percentage of sales (est.) of private label
• Keyword(s):
‘private label’, ‘sale’
- For non-food products only - applies only to selected industries
- For Consumer Staples
o Food manufacturer: private label percentage is at 100%. The
reason is that the company manufacture their product
themselves.
o Retail - Food & Staples: Make sure to double check the
company disclosure. Some companies disclose that they
offer a lot of private labels in their gross sales. On other
cases, in absent of those disclosure 20% private label
percentage can be consider.
o Packaged Foods & Meats: check geographic classification
or companies’ geographic footprint where they are
manufacturing size or the cater, you can use that as a gap
as a benchmark.
o Note: Retain the figure if there is no evidence. In addition,
there will be some companies disclose that they don’t have
a private label hence we could retain the 0% but make sure
to put in internal notes.
- For Technology Hardware
o How much hardware product prompt as the percentage of
revenue overall?
It is mostly it is 100%, where it won’t be 100% when the

o
company has other business segment where there is no
technology hardware manufacturing product state place.
• Example: If the company disclose 20% revenue as a
services or software. That’s when we can exclude
from 100%.
- For Consumer Discretionary (Household Durables and Leisure Commented [ACJ117]: Pending with Content
Products) and Retail Consumer Discretionary
For the final guidance (discussion with RLS)
o Disclose their private label percentage or if not then can be
also estimate. *Follow the current procedure*
Commented [LRA118R117]: This is to be confirmed
Estimated percentage of sales from products manufactured in developing with Content?
countries
• Definition: Indicates the percentage of sales from products manufactured
in developing countries.
• Keyword(s):
sale, manufacturing, outsourcing, suppliers, manufacturing location, List of
Markets
- Emerging and Frontier Market can also be considered
- For Technology Hardware
o Company may clearly mention if the product outsources in
China or Mexico or they may say it is 100% production as in
house, so we change the percentage based on company
disclosure.
o There is some instance that the company discloses unclear
or lack of evidence in percentage then we can assume that
product manufacture in developed market then we can give
it 50%.
• Example: if the company disclose, they are 100%
hardware maker that can be outsourced to
developing market. But when there is non-hardware
product that when we can exclude from 100%
• Example: if the company explicit disclose that some
portion of their revenue in-house then we deducted
in 100%
- For Consumer Discretionary (Household Durables and Leisure Commented [ACJ119]: Pending with Content
Products) and Retail Consumer Discretionary
For the final guidance
o In some instance, wherein they indicate where these are

being manufacture. Current procedure it is revenue-based
product outsourced in developing market and the location
of the manufacturers should be taken as consideration.
Practices Commented [ACJ120]: Pending with Market Experts
Direct engagement of suppliers in establishing fair working conditions

• Definition: Indicates if company engages with its suppliers in establishing
fair working conditions
(a) Company participates in projects with recognized organizations (e.g.,
Better Work projects) and has direct engagement programs with selected
suppliers
(b) Company has direct engagement programs with selected factories or
growers
(c) General reference to direct engagement projects
(d) No evidence
• Keyword(s):
‘fair working’
- Scoring
o Company participates in projects with recognized
organizations and has direct engagement programs with
selected suppliers – Select this option if company has
engagement with its suppliers AND participates in projects with
organizations such as Better Work Projects
o Company has direct engagement programs with selected
factories or growers – Select this option if company has
engagement with its suppliers but does not participate in
projects with organizations such as Better Work Projects
o General reference to direct engagement projects – Select this
option if company generally disclose that it has engagement
with its suppliers (no further details)
China A
Performance incentives for suppliers to abide with policies

• Definition: Indicates if company has performance incentives for suppliers
to abide with policies
(a) Preference shown for suppliers demonstrating superior labor
management performance (e.g. factor is included in supplier "scorecard"
along with price and quality)
(b) General statement that labor management performance is a factor in
awarding and extending contracts
(c) Labor management performance only used in initial screening for first-
time suppliers
(d) Not Disclosed
• Keyword(s):
‘performance incentives’
- Scoring
o Preference shown for suppliers demonstrating superior labor
management performance – Select this option if company has
sufficient disclosure regarding performance incentives. This
should include detailed information regarding suppliers'
performance
o General statement that labor management performance is a
factor in awarding and extending contracts – Select this option
if company has performance incentives for its suppliers, but no
further details disclosed
o Labor management performance only used in initial screening
for first-time suppliers – Select this option if performance
incentives only apply to the initial screening of first-time
suppliers
China A
Practices - Scope of supplier audits

Scope of supplier audits
• Definition: Indicates the company’s scope of supplier audits
(a) No evidence of compliance audits
(b) General statement / no detail
(c) Yes - Auditors are internal OR third-party OR not specified

(d) Yes - Both internal and third-party auditors
• Keyword(s):
‘audit’, ‘supplier’
- Scoring
o No evidence of compliance audits – Select this option if there
is no evidence
o General statement / no detail – Select this option if suppliers
are being audited but no further details provided
o Note: if this was scored hence “Reference to supplier
audits without details on scope” should score as Yes
o Yes - Auditors are internal OR third-party OR not specified –
Select this option if suppliers are being audited by an internal
auditor OR third-party auditor
o Note: if this was scored hence one of the “Tier 1-3
supplier audit” can be score as Yes
o Yes - Both internal and third-party auditors – Select this option
if suppliers are being audited by and internal auditor AND third-
party auditor
o Note: if this was scored hence one of the “Tier 1-3
supplier audit” can be score as Yes
Tier 1 supplier audits (Final product Tier 2 suppliers audits (Components) Tier 3 suppliers audits (Raw
assembly) Materials)
‘Tier 1’, ‘supplier’, ‘audit’, ‘SEDEX’, ‘BSCI’, ‘Tier 2’, ‘supplier’, ‘audit’ ‘Tier 3’, ‘supplier’, ‘audit’, ‘raw
Keywords
‘ICS’ materials’
(a) No (a) No (a) Yes - Includes at least some
(b) Yes - Some percentage of Tier 1 (b) Audits include Tier 2 suppliers Tier 3 suppliers
suppliers only (components) (b) No
Dropdown Options
(c) Yes - Almost all Tier 1 suppliers or
"high risk" suppliers identified through
rigorous systematic analysis
Need to identify if Tier 1, 2 or 3 suppliers are being audited. For Tier 1, need to identify which of these suppliers are
General Procedure
being audited. Should be explicitly disclosed for Yes - Almost all or "high risk" suppliers
Choose ‘Yes - Some percentage of Tier Choose ‘No value’ for Choose ‘No’ if the company is a
1 suppliers only’ if the company is a manufacturers/ ‘No’ for retailers if member of one of below
member of one of below initiatives. the company is a member of one initiatives.
-SEDEX - Supplier Ethical Data of below initiatives. -SEDEX - Supplier Ethical Data
Exchange, -SEDEX - Supplier Ethical Data Exchange,
- BFC - Better Factories Cambodia Exchange, - BFC - Better Factories
-BSCI - Business Social Compliance - BFC - Better Factories Cambodia
Additional Procedure
Initiative, OR Cambodia -BSCI - Business Social
-ICS - Initiative for Compliance and -BSCI - Business Social Compliance Initiative, OR
Sustainability Compliance Initiative, OR -ICS - Initiative for Compliance
-ICS - Initiative for Compliance and Sustainability
and Sustainability
For Technology Hardware: to
avoid double-counting vs.
Guidelines for Specific Industry / Controversial Sourcing KI, we

Market should not give credits to conflict
Industry Guidelines minerals (3TG) related audit - this
Industry: Food & Staples Retailing is mineral tracing related
Default Scoring: leave data point (common pitfall). Should be
as "No Value”. Score only in case explicitly related to labor standards
of Tobacco Issuer. related audits. This is usually
considering the labor conditions
measuring extent of labor
protection and how the company
manages if the company have a
weak labor in their geographic
manufacturing.
Note for Tier 1-3 Supplier audits: If the “Reference to supplier audits without details
on scope” was answered as Yes hence this should be scored as No value. In
addition, if one of the Tier was answered as Yes then the other Tier doesn’t have
audits disclosure then can be scored as No
Reference to supplier audits without details on scope

• Definition: Indicates if company has performance incentives for suppliers
to abide with policies
(a) Yes
(b) No
(c) Not Disclosed
• Keyword(s):
‘audit’, ‘supplier’
- Select Yes if company provided a general statement regarding supplier
audit.
- Note: If the Tier 1-3 Supplier audits was answered as Yes hence this
should be scored as No value.
Industry Guidelines
- Industry: Food & Staples Retailing
Extent of disclosure on instances of supplier non-compliance or violations

of Code of Conduct
• Definition: Indicates if the company publicly report instances of suppliers'
non-compliance or any violations of the code
(a) Does not report any information on instances of non-compliance
(b) Reports some information on instances of non-compliance but not in

detail on types or frequency of violations
(c) Reports detailed instances of non-compliance including types and
frequency of violations
• Keyword(s):
‘violation’
- Scoring
o Does not report any information on instances of non-
compliance – Select this option if company does not report any
information
o Score if the company is a member of one of below
initiatives.
▪ SEDEX - Supplier Ethical Data Exchange,
o Reports some information on instances of non-compliance but
not in detail on types or frequency of violations – Select this
option if company disclosed non-compliance and/or violations
but no further details provided
initiatives
▪ BFC - Better Factories Cambodia
o Reports detailed instances of non-compliance including types
and frequency of violations – Select this option if there is a
detailed information regarding suppliers' non-compliance
and/or violations
initiatives.
▪ ICS - Initiative for Compliance and Sustainability
Action taken by the company to address issues of non-compliance

• Definition: Indicates the action being taken by the company to address
non-compliance (corrective action)
(a) Company does not report any information on corrective actions
(b) General statement
(c) Detailed action plan to correct specified issues
• Keyword(s):
‘corrective action’, ‘non-compliance’
- Scoring
o Company does not report any information on corrective

actions – Select if no disclosure found
o General statement – Select if corrective action is disclosed but
no further details provided
o If only mention contractual obligations from those
suppliers, then only consider this as General Statement
o Detailed action plan to correct specified issues – Select if
company have detailed corrective action to measures and have
clear targets on how they will correct and improve their supplier
compliance practices
o Sample disclosure: Engage with their supplier to
predict those issue staff compliance and adhere their
corrective actions
initiatives.
▪ SEDEX - Supplier Ethical Data Exchange,
▪ BFC - Better Factories Cambodia
▪ ICS - Initiative for Compliance and Sustainability
Practices - Code of Conduct covers the following:

Description* Yes No
Data point
work that is performed involuntarily and under the - Select ‘Yes’ if there is an Select No if
Forced Labor
menace of any penalty evidence the company’s code of no evidence
work that deprives children (any person under 18) of conduct covers forced labor, child found.
Child Labor their childhood, their potential and their dignity, and that labor, working hours, paid
is harmful to their physical and/or mental development. overtime, minimum wage, anti-
regulated hours of work, daily and weekly rest periods, discrimination, freedom of
Working Hours association, or health & safety.
and annual holidays.
all hours worked in excess of the normal hours, NOTE: To consider the code of
unless they are taken into account in fixing renumeration conduct of the company make
Paid Overtime sure to have explicitly mention
in accordance with custom [Reduction of Hours and
Work Recommendation, 1962 (No. 116)] that they extent to their supplier or
the minimum amount of remuneration that an employer third party.
Code of Conduct is required to pay wage earners for the work performed
Minimum Wage Select ‘Yes’ if the company is a
covers during a given period, which cannot be reduced by
collective agreement or an individual contract. member of one of below
as any distinction, exclusion or preference made on the initiatives.
basis of race, color, sex, religion, political opinion, - SEDEX - Supplier Ethical Data
national extraction or social origin (among other Exchange
Anti-Discrimination - BFC - Better Factories
characteristics), "which has the effect of nullifying or
impairing equality of opportunity and treatment in Cambodia
employment or occupation". - BSCI - Business Social
right of workers and employers to form and join Compliance Initiative, OR
Freedom of Association organizations of their own choosing is an integral part of - ICS - Initiative for Compliance
a free and open society. and Sustainability
workers must be protected from sickness, disease and
Health & Safety
injury arising from their employment.
*Source: ILO.org
Training of suppliers on the Code of Conduct and/or specific labor-related

issues
• Definition: Indicates that the company has taken steps to train suppliers
on the Code of Conduct and/or specific labor-related social issues
(a) Yes
(b) No
(c) Not Disclosed
• Keyword(s):
‘training’
- Select Yes if company has taken step on training of suppliers on the
Code of Conduct and/or specific labor-related issues
Supplier selection based on labor management performance

• Definition: Indicates that the company has taken steps to train suppliers
on the Code of Conduct and/or specific labor-related social issues
(a) No
(b) Labor management performance only used in initial screening for first-
time suppliers
(c) General statement that labor management performance is a factor in
awarding and extending contracts
(d) Preference shown for suppliers demonstrating superior labor
management performance (e.g. factor is included in supplier "scorecard"
along with price and quality)
• Keyword(s):
‘supplier’, ‘labor management’ ‘management’
- Answer the question, “Is labor management performance a factor in
selecting new suppliers or awarding new contracts with existing
suppliers?”
- Some companies disclose an extensive document including all the
preferences that they want for their suppliers such as Walmart, TESCO.
We can check out the document to confirm if labor management
standard is included the way they select suppliers. It’s not that common
but we could check if there is an exist document.
Practices – Supply Chain Policies Commented [ACJ121]: Pending with Market Experts
Scope of the policy addressing labor rights in its supply chain

emissions and/or improve energy efficiency of its supply chain (upstream)
(a) Policy includes standard ILO core conventions, plus fair wage or living
wage commitments
(b) Policy covers standard ILO core conventions (minimum wage, paid
overtime, extent of overtime, child labor, forced labor, freedom of
association) Commented [LRA122]: A – ILO core conventions AND
(c) General commitment to abide to labor and safety laws fair wage or living wage commitments
B – ILO core conventions only
(d) No evidence of policy
• Keyword(s):
‘ILO’, ‘fair wage’, ‘minimum wage’, ‘overtime’, ‘child labor’, ‘forced labor’,
freedom of association’
Scope of workplace safety policy provisions for suppliers

• Definition: Indicates the scope of workplace safety policy provisions for
suppliers.
(a) Policy covers building safety, fire safety, and workplace safety
procedures and equipment for workers
(b) Policy covers only workplace safety procedures and equipment for
workers
(c) General reference to safety in the policy
• Keyword(s):
‘workplace safety’
Policy related to sub-contracting

• Definition: Indicates the policy related to sub-contracting.
(a) Sub-contracting is prohibited
(b) Company is responsible for sub-contractor selection and compliance
verification
(c) Suppliers are responsible for sub-contractor selection and compliance
verification
• Keyword(s):
‘sub-contracting’
Practices – Compliance assurance programs Commented [ACJ123]: Pending with Market Experts
Scope of direct supplier audits on their labor practices and compliance

with Code of Conduct
• Definition: Indicates the extent of direct supplier audits on their labor
practices and compliance with Code of Conduct
(a) All critical suppliers audited (i.e. all suppliers, which form top 80% by
cost of supplies)
(b) Selected critical suppliers audited (i.e. between 30 and 50% of critical
suppliers)
(c) General statements on supplier audits on their labor practices
(d) No evidence of direct suppliers' audits
• Keyword(s):
‘audit’, ‘labor practices’
China A
Scope of components or raw materials suppliers audits on their labor

practices and compliance with the company's policies
• Definition: Indicates the extent of components or raw materials suppliers’
audits on their labor practices and compliance with the company's policies
(a) Most of key materials suppliers
(b) Evidence of some indirect suppler audits
(c) No evidence of indirect suppliers' audits
• Keyword(s):
‘audit’, ‘raw materials’
Performance – Supply Chain Transparency Commented [ACJ124]: Pending with Market Experts
Extent of supply chain transparency

• Definition: Indicates the extent of supply chain transparency (e.g., number
or location of direct suppliers, component suppliers, and/or subcontractors
or licensed producers)
(a) Number and location of direct suppliers, component suppliers, and/or
subcontractors or licensed producers
(b) Number and location of direct suppliers
(c) Total number of suppliers and general reference to regions of
production
(d) Number and location of suppliers are not disclosed
• Keyword(s):
‘direct suppliers’, ‘component suppliers’, ‘subcontractors’, ‘licensed
producers’
China A
Level of transparency around direct supplier audit findings

• Definition: Indicates the level of transparency around direct supplier audit
findings
(a) Company reports number of percentage of suppliers that exceed, meet,
or fail to meet code requirements
(b) General statement of suppliers' compliance
(c) Findings are not disclosed
• Keyword(s):
specific guidance.
Supply Chain Transparency – Number and type of suppliers
Year Number of direct suppliers Number of component or Number of licensed or sub-

(finished goods) raw material suppliers contracted producers
Indicates the year Indicates the total number of Indicates the total number of Indicates the total number of
Definition of the reporting direct suppliers (i.e., finished component or raw material licensed or sub-contracted
period goods) suppliers. producers.
Dropdown Option N/A N/A – Numeric value N/A – Numeric value N/A – Numeric value
N/A ‘suppliers’, ‘final product’, ‘suppliers’, ‘raw materials’ ‘sub-contractor’
Keyword
‘finished goods’
Provide the - Answer if the company is a - Answer if the company is a - Answer if the company is a
General Procedure
reporting year. China A issuer. China A issuer. China A issuer.
Supply Chain Transparency – Scope of code compliance as

verified by the audits
Year Percent of suppliers meeting or exceeding code
requirements
Indicates the year of the reporting Indicates the total number of component or raw material
Definition
period suppliers.
Dropdown Option N/A – Numeric value N/A – Numeric value in percentage
Keyword N/A ‘supplier’, ‘meeting’
General Procedure Provide the reporting year. - Answer if the company is a China A issuer.
Toxic Emissions & Waste

This issue evaluates the extent to which companies may face water shortages
affecting their ability to operate, lost access to markets due to stakeholder water
conflicts, or higher water costs. Scores are based on exposure to water-stressed
basins and water-intensive segments; water management strategy and targets; water
use over time and vs. peers; and controversies.
Performance
Air Emissions
• General Procedure on Air Emission
- Place the value of the company’s air emissions / releases to land for
the particular year.
- Ensure that the data is NOT on AVOIDED, REDUCED, or SAVED
emissions since the data point is asking for the emissions that were
released by the company
- NOTE: Please do refer in Additional Guidance for FAQs
NOx Performance SOx Performance Mercury Performance Ozone Depleting Substances

Performance
Definition NOx emissions of the SOx emissions of Mercury emissions of the emissions from Ozone Depleting
company the company company Substances used by the company
Keywords NOx, Nitrogen Oxide SOx, Sulfur Oxide Mercury, Hg Ozone Depleting Substances, CFC,
chlorofluorocarbon, fluoromethane,
fluoropropane, fluoroethane
Particulate Matter VOC Performance Dioxins Performance Metals (Ni,Cr,VI,Pb,Co) Performance

Performance
Definition Particulate Matter VOC emissions of dioxins emissions of the air emissions from metals used by the
emissions of the the company company company
company
Keywords Particulate matter, PM, VOC, volatile organic Dioxin, POP, Persistent Organic Metal emission, Ni, Nickel, Cr, Chromium,
dust, soot, fine dust compound Pollutant Chromium (VI), (Cr (VI)), Pb, Lead, Co,
Cobalt
• Specific Guidance for Releases to Land: Particulate Matter Performance
Industry Guidelines
- Sub-Industry/Sector: Metals & Mining Industry and Utilities Sector
- Specific Guidelines: if the company discloses several PM sizes (i.e.
PM2.5, 10), use PM10
Releases to Land
• General Procedure on Releases to Land
- Place the value of the company’s air emissions / releases to land for
the particular year.
- Ensure that the data is NOT on AVOIDED, REDUCED, or SAVED
emissions since the data point is asking for the emissions that were
released by the company
- NOTE: Please do refer in Additional Guidance for FAQs
Non-hazardous Waste Performance

• Definition: Indicates the non-hazardous waste released by the company
• Keyword(s):
non-hazardous waste, non-hazardous, tailing
- We will only take the wastes generated by the company.
- We will not take that data if wastes came from accepted materials for
recycling from other companies.
- We will not take the waste subcontracted for disposal to third-party
data unless it is explicitly stated that the waste is generated by the
company.
- These should be waste that have been landfilled or disposed of in any
other way except through reuse, recycling, repurposing. Exclude from
the count wastes that have been reused
- Case #1: There are disclosures where the company categorize waste
as Scheduled and Non-Scheduled.
o Scheduled Waste - any wastes that possess hazardous
characteristics and have the potential to adversely affect to
the public health and environment. There are 77 types of
scheduled wastes listed under First Schedule of
Environmental Quality (Scheduled Wastes) Regulations
2005 and the management of wastes shall be in accordance
with the provisions of the above Regulations.
o Non-Scheduled Waste - The waste has classified based on
the following consideration: The waste has been widely
used as raw material to produce product that is safe to be
used; The waste does not exhibit significant toxic
characteristics; The waste is not classified as hazardous
waste at international level. E.g., plastic, paper, glass, metal
• Source: SCHEDULED & NON-SCHEDULED
WASTE MANAGEMENT – Notion Consortium
o Given the definition above, we should consider scheduled

waste as hazardous and non-scheduled as non-hazardous.s
Industry Guidelines
- Sub-Industry: Metals & Mining and Steel
o Only consider TAILINGS waste for this data point. Non-
Hazardous waste, waste rock, or Tailing’s waste combined
other wastes are NOT considered.
o Leave BLANK if the company does not generate tailings/no
data/combined with other types of waste.
- Sector /Industry: Chemical Industries, Utilities Sector, Oil & Gas

Industries
o if there is breakdown, take the landfilled waste only (exclude
reused, recycled, incinerated)
o if no breakdown, take all values as disclosed
- Sub-Industry/Sector: Industrials Sector and other industries/sector

(excluding Chemical Industries, Utilities Sector, Oil & Gas Industries)
o if no breakdown, take all values as disclosed
Hazardous Waste Performance

• Definition: Indicates the hazardous waste released by the company
• Keyword(s):
hazardous waste, hazardous
- We will only take the wastes generated by the company.
- We will not take that data if wastes came from accepted materials for
recycling from other companies.
- We will not take the waste subcontracted for disposal to third-party
data unless it is explicitly stated that the waste is generated by the
company.
- These should be waste that have been landfilled or disposed of in any
other way except through reuse, recycling, repurposing. Exclude from
the count wastes that have been reused
- Case #1: There are disclosures where the company categorize waste
as Scheduled and Non-Scheduled.
o Scheduled Waste - any wastes that possess hazardous
characteristics and have the potential to adversely affect to
the public health and environment. There are 77 types of
scheduled wastes listed under First Schedule of
Environmental Quality (Scheduled Wastes) Regulations
2005 and the management of wastes shall be in accordance
with the provisions of the above Regulations.
o Non-Scheduled Waste - The waste has classified based on
the following consideration: The waste has been widely
used as raw material to produce product that is safe to be
used; The waste does not exhibit significant toxic
characteristics; The waste is not classified as hazardous
waste at international level. E.g., plastic, paper, glass, metal
• Source: SCHEDULED & NON-SCHEDULED
WASTE MANAGEMENT – Notion Consortium
o Given the definition above, we should consider scheduled
waste as hazardous and non-scheduled as non-hazardous.
High-level Radioactive Waste Performance

• Definition: Indicates the radioactive waste released by the company
• Keyword(s):
radioactive waste, radioactive
- Provide the High-level Radioactive Waste of the company.
Releases to Water: Water Effluents Performance

• Definition: This data point refers to the water discharge of the company.
(VOLUME of water discharged by the company, not the quality.)
Units: acre-ft (acre feet), bbl (barrels), bushel, cord, ft3 (cubic feet), gal (gallon),
imperial gal (imperial gallon), km3 (cubic kilometer), liter, m3 (cubic meter),
million m3, t (metric tonnes/tonnes)
• Keyword(s):
Water discharge, Water effluent
Document type
- Do not convert data from one unit to another (example: from gallons to
m3), place data as disclosed by company
Exceptions (you may convert the following to m3):
• 1 megaliter (ML) = 1,000 m3
• 1 ton water (t) = 1 m3 [Note: ensure that ton is metric
tons and not short tons]
• 1000L (liter) = 1 m3
o Avoid using million m3 and instead convert the data to m3
- Scoring:
o Place the value of the company’s water effluents/water
discharge for the particular year. This data point should only be
for wastewater that is contaminated/already used.
o If company disclosed that their water discharge was only for
cooling or heating, do not fill this table.
o Ensure that the data is NOT on water quality (BOD, COD,
Dissolved Oxygen, pH, etc.) and it must be the company’s Water
Discharge.
Additional Guidance for Air Emission, Releases to Land, and Releases to

Water
Restated Data Air Emission, Releases to Land, and Releases to Water

• If the company has undergone a Corporate Action Event (e.g.,
divestment/acquisition/merger/restructuring) and has restated its historical
toxic emissions based on a CHANGE IN SCOPE, please do NOT restate
historical values.
• Historical values can be changed ONLY if the company made an error in the
previous year and has reported correct values with the SAME scope.
• If the latest report has been restated, use the restated values, then update in
the Internal Notes the original values.
Important Rule of Units in Air Emissions and Releases to Land

• Units: Mt (mega ton), a.m.u (Atomic Mass Unit), carat, g (grams), grain, kg
(kilo/kilograms), lb (pounds), mg (milligrams), oz (ounce), short ton (metric
tons/US ton/ton/short ton), t (metric tonnes/tonnes), ug (microgram)
• Do not convert data from one unit to another (example: from pounds to kg),
place data as disclosed by company
• For duplicate unit dropdowns in Capture for the following: mg, oz, short ton, t,
you may use either duplicate unit
- Be careful of units used by the company in their data tables
Month Year
o Companies usually disclose what their units mean/signify in the

footnotes or the tabular data was stated in words in a paragraph
within the document.
o There could be cases that even historical data units are incorrect;
in this case, change the units once confirmed that the units were
placed incorrectly in the table and indicate the error in the Internal
Notes
o MT, metric tons, metric tonnes, tonnes
• Company sometimes discloses "MT" but they actually mean
"tonnes" or "metric tonnes/metric tons" [all of which falls
under the "t" unit in Capture] instead of
"megatonnes/megatons" [falls under the "Mt" unit in
Capture].
o Tons
1. For US companies
• Use “short ton” unit in Capture if the company reported unit
is tons.
• For validation, identify what units the company uses for their
other data (metric units vs imperial units).
• If the company uses pounds, gallons, ounce in their other
data, use “short tons” unit in Capture because they disclose
their data in the imperial unit system
• If the company disclosed their other data as liters, cubic
meters, kg, grams, then we use “t” since the company
discloses data in the metric unit system
2. For non-US companies OR US companies with operations
outside the US
• Use “t” unit in Capture if they disclosed their data in tons.
Provide Internal Notes.
• For validation, identify what units the company uses for their
other data (metric units vs imperial units).
• If the company uses pounds, gallons, ounce in their other
data, use “short tons” unit in Capture because they disclose
their data in the imperial unit system
• If the company disclosed their other data as liters, cubic
meters, kg, grams, then we use “t” since the company
discloses data in the metric unit system
• Specific Guidance for Units

Industry Guidelines
- Sub-Industry/Sector: Oil & Gas Sector, Metals & Mining Industry,

Industrial Machinery Industry
o Please input issuer's performance on all TEW parameters (NOx,
SOx, VOC, Hazardous Waste) only in tonnes (t) in Capture.
o In case the issuer has reported data in some other units, then
those performance metrics should be converted to tonnes (t)
which should then be input in Capture.
- Example:
o metric to metric units, convert to tonnes; English unit [e.g. short
tons] to metric, you may refer to Google conversions. Always
indicate in Internal Notes
Performance – Waste Generation & Recycling

Total Waste Quantities (tons)
• Definition: This data point refers to the total waste generated by the company.
N/A – free text
• Keyword(s):
Total Waste, Waste
- Ensure that unit is in tons
- Place the value of the company’s total waste generated for the
particular year. Ensure that the data is NOT on AVOIDED, REDUCED, or
SAVED waste
- This must be the sum of all waste generated by the company
China A
This is a China A data point and only scored if issuer is a China A
Title of other toxic emissions & waste category
• Definition: This data point refers to other toxic emissions & waste by the
company.
N/A – free text
• Keyword(s):
Toxic emissions, air emission, waste
- Scoring:
Place the category of the other toxic emissions & waste data of
o
the company that are NOT found in the pollutant categories in
Capture
- This is filled in if Other toxic emissions & waste quantities data point
is filled
China A
Other toxic emissions & waste quantities

• Definition: This data point refers to the value of the other toxic emissions &
waste by the company.
N/A – free text
• Keyword(s):
Toxic emission, air emission, waste
- Since there are no unit dropdowns, provide the values with the units as
well in the Internal Notes
- This is filled in if Title of other toxic emissions & waste category data
point is filled
- Scoring:
o Place the value of the other toxic emissions & waste data
provided by the company that are NOT found in the pollutant
categories in Capture
China A
Percentage of Total Waste Recycled

• Definition: This data point refers to the total waste recycled by the company.
N/A – free text
• Keyword(s):
Recycled waste, waste recycled, recycled
- Scoring: Place the value of the Total Waste Recycled by the company
China A
Industry Metric Value

• Definition:
N/A – free text
• Keyword(s):
- Scoring: Kindly leave this Blank
Industry Metric Unit
• Definition:
N/A – free text
• Keyword(s):
- Scoring: Kindly leave this Blank
Practices – Governance and Strategy

Scope of policies to address environmental impact (air emissions, water
discharges and waste)
• Definition: This data point refers to the scope of commitments of the
company’s policy on addressing environmental impact.
(a) No
(b) Limited policies
Standard statements or commitmentsInvestments related to increased connection of
renewable power to electric grid
(c)
(d) Significant commitments in key areas
(e) Comprehensive policies in all key areas
• Keyword(s):
Waste, Water discharge, air emissions, toxic emission, environmental impact,
environmental policy
- The disclosure might come from the company’s environmental policy
or paragraphs/statements in a company's AR/CSR report (scored
depending on comprehensiveness of disclosure)
- Scoring:
o No – no disclosure or no mention of environmental issues
o Limited policies – basic statements on a limited number of
areas covered by this benchmark (example: only a statement on
the reduction of on specific type of emissions or waste)
Standard statements or commitments – standard statements

o
on most areas covered by this benchmark
o Significant commitments in key areas – statements + policies +
examples of targeted efforts in most key areas covered by this
benchmark
o Comprehensive policies in all key areas – shows clear and
comprehensive strategy to address environmental pollution
issues: statements + policies + examples of targeted efforts in
all key areas covered by this benchmark
Industry Guidelines
- Industry: Industrial Machinery and Electrical Equipment industry
- Specific Guidance in Scoring:
o Limited policies – General commitments that do not address
ALL relevant indicators
o Standard statements or commitments – General commitment
to reduce VOC, Hazardous Waste, and Waste, but unclear
implementation
o Significant commitments in key areas – Company has policies
to reduce VOC, Hazardous Waste, and Waste - implementation
plan ignoring one category, but otherwise strong strategy in
other areas
o Comprehensive policies in all key areas – Company has policies
to reduce VOC, Hazardous Waste, and Waste; outlines clear
initiatives to improve on all KPIs
- Sector: Utilities
o Comprehensive policies in all key areas or Significant
commitments in key areas – this can be score if the company
disclose quantitative targets.
o Standard statements or commitments – without the
quantitative targets
- Sub-Industry: Pharmaceuticals and Biotechnology

- Specific Guidance: This policy should refer to waste that is generated
during the manufacture of pharmaceuticals / APIs / other drugs.
China A
o Limited policies – In case no specific policies or statements
found for an issuer, if it’s a ‘Clean Production Company’ (清
洁生产企业) or classified as heavy pollutant discharging

entity (重点排污单位), use Limited policies as minimum
default scoring if the above conditions are fulfilled. You can
go to the company website and 许可信息公开 (mee.gov.cn)
to verify if it has disclosed pollutant discharging
information.
- Source:
o Law on Promotion of Clean Production (清洁生产促进法)
and Regulation on Pollution Discharge Administration（排
污许可证管理条例）
o 许可信息公开 (mee.gov.cn)
Evidence of an Environmental Management System (EMS)

• Definition: This data point refers to the presence of an Environmental
Management System (EMS) within the company’s operations.
(a) EMS across all relevant operations
(b) EMS across selected operations
(c) General statements on having an EMS/ environmental certification
(d) No evidence
• Keyword(s):
EMS, Environmental Management System, ISO 14001
- ISO 14001 certification is not necessary, but this certification can also
merit a score in this data point (ISO 14001 is a type of EMS)
o Ensure that they have obtained the certification mentioned by the
company and they are not only complying / adhering/ following
the standards of the certification
• Ensure that the certification is not yet expired;
expired certifications are NOT valid
o Kindly base the score on company disclosure. Double check
previous years' reports (or analyst notes) if ISO 14001 or EMS is
there; sometimes companies may not mention some systems in
succeeding years (usually, EMS is ingrained into the company's
system for a long time, and they might only be updated based on
audit findings or changing company contexts).
- Scoring:
EMS across all relevant operations – all operations by the

o
company has an Environmental Management System in place or
if company has ISO 14001 certification in all their operations
o EMS across selected operations – only few operations have an
Environmental Management System in place or if company has
ISO 14001 certification in their selected operations (but scope of
certification is limited or not mentioned)
o General statements on having an EMS/ environmental
certification – the company stated that they have an EMS with
no specific scope mentioned or if they generally mentioned an
environmental certification (no other supporting statements on
the scope or the kind of environmental certification)
China A
- If the issuer is recognized as a ‘Clean Production’ company (清洁生产
企业), first verify the scope of such recognition, and reach out to
market experts for scoring guidance
o General statements on having an EMS/ environmental
certification - If the issuer is a heavy pollutant discharging
entity (重点排污单位) can give minimum credit
Percentage of sites with hazardous waste guidance that achieved

HAZWOPER certification or follow ISO 14001 for waste management
operations that are certified to ISO 14001 or HAZWOPER certification.
N/A – free text
• Keyword(s):
- Scoring:
o Write the percentage of the company’s operations certified to
ISO 14001 or HAZWOPER certification.
company and they are not only complying / adhering/ following
the standards of the certification
•
Ensure that the certification is not yet expired;
o If percentage is not provided by the company, use:
• [Total # of sites certified/Total # of sites in the
company] * 100
▪ NOTE: When calculating, ensure that the
total number of sites are provided by the
company or identifiable.
▪ do not make assumptions on the Total # of
sites in the company nor on the Total # of
sites certified.
o If percentage cannot be identified or vaguely disclosed, leave this
data point blank
Industry Guidelines
- Industry: Metals & Mining
o It is preferred to do the estimate based on production
output/capacity, reserves or revenue breakdown per site.
o If any of these data are not available, only then could we use the
# of sites.
o These are usually found in CSR reports or AR reports
o For estimations, ensure that estimation method is discussed in
the Internal Notes
Disclosure around the number or percentage of sites with HAZWOPER or

ISO 14001 certification
• Definition: This data point refers to how the company disclosed the
percentage of sites/operations that has a HAZWOPER or ISO 14001
certification.
(a) Estimated
(b) Disclosed
• Keyword(s):
- If percentage cannot be identified or vaguely disclosed, leave this data
point as No Value
- Ensure that they have obtained the certification mentioned by the
company and they are not only complying/adhering/following the
standards of the certification
o Ensure that the certification is not yet expired; expired

certifications are NOT valid
- Scoring:
o Estimated – the percentage was manually calculated and was
not provided by the company
o Disclosed – the percentage was disclosed by the company
Extent of programs to reduce toxic release footprint associated with

supply chain
• Definition: This data point refers to the reach of the company’s programs on
reducing toxic release footprints within their supply chain.
(a) Not disclosed
(b) A few initiatives with suppliers
(c) Suppliers subject to performance screening and audits
• Keyword(s):
Supplier emission, supply chain, footprint, supplier
- Scoring
o Not disclosed – no evidence
o A few initiatives with suppliers – the company has
efforts/initiatives/programs on reduction of toxic releases those
suppliers in their supply chain must adhere to (use this score
even if scope of suppliers were not mentioned but there is some
evidence of initiatives)
o Suppliers subject to performance screening and audits – the
company requires screening and audits of their suppliers if they
adhere to the programs/efforts/initiatives of the company on
toxic releases
Industry Guidelines
- Sector: Utilities
- Scoring: leave at No Value
- Industry: Chemicals and Electrical Equipment

- Scoring: leave at No Value
Regular audits of environmental impact of its operations

• Definition: This data point refers to the frequency and type of environmental
audits conducted within the company’s operations.
(a) External independent audits of all relevant operations conducted at least
once every three years
(b) External independent audits of selected operations conducted at least once
every three years
(c) Internal audits of all relevant operations at least once every three years
(d) Internal audits of selected operations at least once every three years
(e) Evidence of audits but no specific details / Audits conducted but not on a
regular schedule
(f) No Evidence
• Keyword(s):
EMS, Environmental Management System, ISO 14001, environmental audit,
environmental inspection, environmental compliance, periodic review, review,
assessment, appraisal
- Ensure that the audits in this case are environmental audits; do not
confuse with other kinds of audits (health and safety audits, financial
audits, etc.)
- ISO 14001 certification can also merit a score in this data point (ISO
14001 certifications require external audits every 3 years)
previous years' reports (or analyst notes) if ISO 14001 or EMS is
there; sometimes companies may not mention some systems in
succeeding years (usually, EMS is ingrained into the company's
system for a long time, and they might only be updated based on
audit findings or changing company contexts).
- Scoring:
o External independent audits of all relevant operations
conducted at least once every three years – audits (external) are
conducted in all operations of the company at least once every
three years; use this score if company is ISO 14001 certified in
all operations
o External independent audits of selected operations conducted
at least once every three years – audits (external) are conducted
in some operations of the company at least once every three
years; you may also use this score if company is ISO 14001
certified in some operations (whether the company listed some
of their certified sites or scope of ISO certified sites are not

mentioned)
o Internal audits of all relevant operations at least once every
three years – audits (internal) are conducted in all operations of
the company at least once every three years; internal audits are
conducted within the company and does not require other third-
party/external auditors
o Internal audits of selected operations at least once every three
years – audits (internal) are conducted in some operations of
the company at least once every three years; if company
mentioned audits and mentioned some sites, use this score.
Internal audits are conducted within the company and does not
require other third-party/external auditors
o Evidence of audits but no specific details / Audits conducted
but not on a regular schedule – the company mentions audits
without any other information on the kind of audit
(internal/external) and/or if audits are conducted on an ad-hoc
basis/sporadically; if the company vaguely mentions audits but
without any other details on frequency, use this score
o No Evidence – no disclosure
Evidence of audits across all locations of operations

• Definition: This data point refers to the presence of environmental audits in all
the company’s operations.
(a) Yes
(b) No
(c) Not Disclosed
• Keyword(s):
environmental inspection, environmental compliance, periodic review, review,
assessment, appraisal
audits, etc.)
- For ISO 14001 certified issuers:
o 100% certified will automatically give a Yes score for this data
point

• Ensure that the certification is not yet expired;
previous years' reports (or analyst notes) if ISO 14001 is there
o If company mentions they audit ALL facilities/sites even if not
100% ISO 14001 certified (especially when they are aiming for
100% certification), score Yes
- Scoring:
o Yes – the company explicitly mentions they conduct audits (even
if not an ISO 14001 certification or EMS certification) but covers
the full geographic scope of the operations
o No – If the company conducts audits but does NOT cover the full
geographic scope of the operations
Evidence of annual compliance audits

• Definition: This data point refers to the presence of annual environmental
audits in the company’s operations.
(a) Yes
(b) No
(c) Not Disclosed
• Keyword(s):
environmental inspection, environmental compliance, annual audit, yearly
audit, yearly inspection, annual inspection, yearly monitoring, annual
monitoring, periodic review, yearly review, annual review, yearly assessment,
annual assessment, yearly appraisal, annual appraisal
audits, etc.)
- For ISO 14001 certified issuers:
o 100% certified will automatically give a Yes score for this data
point
•
Ensure that the certification is not yet expired;
previous years' reports (or analyst notes) if ISO 14001 is there
- Scoring:
o Yes – If the company explicitly mentions that their EMS audits
occur on a yearly basis and that all sites have constant
monitoring
o No – audits occur only every two years or less
Practices – Targets
NOTE: CO2, Carbon Dioxide, Carbon, Scope 1, 2, and 3 targets, and coal power
plant/power plant phase-out targets are NOT valid under Practices – Targets data
point (they fall under the Carbon targets which are different from toxic
emissions/waste targets)
Demonstrated track record of achieving its toxic emissions targets

• Definition: This data point refers to how the company has performed in their
previous toxic emission targets.
(a) No previous targets
(b) Largely failed to meet previous targets
(c) Mixed record of meeting previous targets
(d) Met previous targets
• Keyword(s):
Waste target, emission target, emissions target, waste reduction target,
emission reduction target, reduction target, target
- Ensure that the company already had targets in the previous years to
score this data point. Current/ongoing targets are not valid
- Ensure that targets are on their toxic emissions/waste targets
- Scoring:
o No previous targets – no evidence of targets/no previous
targets
o Largely failed to meet previous targets – previous targets by the
company were mostly not met (failed to achieve targets)
o Mixed record of meeting previous targets – company has
achieved some targets but also failed to meet some of their
targets
o Met previous targets – company has met ALL their previous

targets
Evidence of ongoing/ future target(s) to reduce toxic emissions and waste

• Definition: This data point refers to the presence of current/ongoing toxic
emissions and/or waste targets in the company’s operations.
(a) Yes
(b) Qualitative evidence
(c) No evidence
• Keyword(s):
- Ensure that targets are on their toxic emissions/waste targets.
Historical and current/ongoing targets are all valid for this data point
- Scoring:
o Yes – company has quantitative targets. For the target to be
quantitative, they should have
• Baseline Year and/or Baseline Year Value and any
of the following: Target Year, Target Year Value,
and a quantitative description of the target (e.g.,
10% reduction of NOx by 2030 compared to 2015
baseline).
• Otherwise, the target will fall under qualitative.
o Qualitative evidence – company only mentioned qualitative
targets (no specific numerical targets mentioned); general
statements on waste/toxic emissions reduction will suffice for
this data point
o No evidence – no targets
• Interlinked Data Point(s) Guideline
- Scoring Yes for this data point will require the analyst to fill in the
Targets table (see Practices – Targets – Toxic Emissions and Waste
Reduction Targets section of this manual)
Industry Guideline
- Sector: Utilities
- Specific Guidelines: Targets on technological advances are valid for a
Qualitative evidence score. Examples are installing scrubbers,
precipitators, flue gas cleaners, etc.
Practices – Targets – Toxic Emissions and Waste Reduction

Targets
NOTE: CO2, Carbon Dioxide, Carbon, Scope 1, 2, and 3 targets, and coal power
plant/power plant phase-out targets are NOT valid under Practices – Targets data
point (they fall under the Carbon targets which are different from toxic
emissions/waste targets)
Baseline Year
• Definition: This data point refers to the year where the company’s toxic
emissions/waste reduction target will be compared to.
N/A – free text
• Keyword(s):
- Scoring:
o Place the year of the value where the company’s Toxic
Emission/Waste target will be compared to (baseline year)
Baseline Year Value

• Definition: This data point refers to the value where the company’s toxic
emissions/waste reduction target will be compared to.
N/A – free text
• Keyword(s):
- Scoring:
o Place the value where the company’s Toxic Emission/Waste
target will be compared to (baseline value)
Implementation Year
• Definition: N/A
N/A – free text

• Keyword(s):
N/A
- Leave this data point Blank
Implementation Year Value
• Definition: N/A
N/A – free text
• Keyword(s):
N/A
Target Year
• Definition: This data point refers to the year when the company aims to achieve
their toxic emissions/waste reduction target.
N/A – free text
• Keyword(s):
- Scoring:
o Place the year of the company’s Toxic Emission/Waste target is
aimed to be achieved
Target Category
• Definition: This data point refers to the category of the company’s toxic
emission/waste reduction target.
(a) Toxic Emissions – Absolute
(b) Toxic Emissions – Intensity
(c) Operational Waste Reduction – Absolute
(d) Operational Waste Reduction – Intensity
(e) Other
• Keyword(s):
-Ensure that targets are on their toxic emissions/waste targets.

- Absolute vs Intensity
o Absolute = actual value of emissions/waste data
o Intensity = waste/emissions data per person, USD, person, etc.
(examples: tons/production, kg per USD, g/production, etc.)
- Scoring:
o Toxic Emissions – Absolute – company’s target is on their
actual toxic emissions values
o Toxic Emissions – Intensity – company’s target is on the toxic
emissions intensity
o Operational Waste Reduction – Absolute – company’s target is
on their actual waste values
o Operational Waste Reduction – Intensity – company’s target is
on waste intensity
o Other – do not use this score.
China A
- Specific Guidelines: SHOULD NOT be No Value when Target Reduction
(%) is filled
Target Scope
• Definition: This data point refers to scope of the company’s operation who will
participate in the toxic emissions/waste reduction target.
(a) Targets covers all relevant segments
(b) Targets covers selected segments
• Keyword(s):
- Scope can sometimes be found on the footnotes under the data tables,
on the company’s “Scope of the Report” or “About the Report” at the start
of their reports, or on the introductory paragraph of their
Environmental/ESG/GRI data section (for ensure that the scope is
pertaining to environmental data or includes environmental data)
- Scoring:
Targets covers all relevant segments – target is for all the

o
company’s operations/sites
o Targets covers selected segments – target is only for a few
operations/sites of the company or if the company mentioned
the sites/operations the target is applied to
o Scope not determinable – no mention on the scope of the
targets
China A
- Specific Guidelines: SHOULD NOT be No Value when Target
Reduction (%) is filled
Target Description
• Definition: This data point refers to the details on the toxic emissions/waste
reduction target.
N/A – free text
• Keyword(s):
- Scoring:
o Place the details/description of the company’s target
Target Year Value

• Definition: This data point refers to the end goal value of the company’s toxic
emissions/waste reduction target.
N/A – free text
• Keyword(s):
- Scoring:
o Place the value of the company’s Toxic Emission/Waste target

• Definition: This data point refers to the percentage of reduction that the
company’s toxic emission/waste reduction target aims to achieve.
N/A – free text
• Keyword(s):
emission reduction target, reduction target, target reduction, target
- Scoring:
o Place the targeted percentage reduction of the company’s
Waste/Toxic emission.
o This formula may be used if the data is available:
• [(Baseline Year Value - Target Year Value)/Baseline
Year Value] *100.
▪ Example: if company's SOx emissions for FY
2019 is 0.30 and they want to reduce it to
0.18 by 2025, the target reduction is going to
be [(0.30-0.18)/0.30]*100 = 40%
Industry Guideline
- Sector: Utilities
- Specific Guidelines: Targets on technological advances are valid.
Examples are installing scrubbers, precipitators, flue gas cleaners, etc.
Per year reduction target - Estimation key

percentage of reduction of their toxic emission/waste reduction target.
(a) Reported
(b) Estimated
• Keyword(s):
- Scoring:
Reported – percentage reduction target was disclosed by the

o
company
o Estimated – percentage reduction target was manually
calculated and not disclosed by the company
Industry Guideline
- Sector: Utilities
Examples are installing scrubbers, precipitators, flue gas cleaners, etc..
China A
• Specific Guidelines: SHOULD NOT be No Value when Target Reduction
(%) is filled
Per year reduction target - Estimation Details

• Definition: This data point refers to the details on the company’s percentage
of reduction that their toxic emission/waste reduction target aims to achieve.
N/A – free text
• Keyword(s):
- Scoring:
o Place the details on the percentage reduction of the company’s
Waste/Toxic emission
Industry Guideline
- Sector: Utilities
China A
Status on achieving target

• Definition: This data point refers to the progress of the company on their toxic
emissions/waste reduction target.
(a) On pace to achieve the ongoing target
(b) Not on pace to achieve the ongoing target

(c) Lack of data, status not determinable (ongoing target)
(d) Exceeded the set target
(e) Achieved the set target
(f) Did not achieve the set target
(g) Lack of data, status not determinable (historical target)
• Keyword(s):
- If it is difficult to determine whether the company is on pace or not on
pace in the target, you may use any of the formulas below
o [(Target Year Value - Current Value)/Remaining Years]
o [(Baseline Year Value - Target Year Value)/Baseline Year Value]
o If the answer seems to achieve or exceed the target, then it's on
pace. If it falls short, then it's not on pace.
- Scoring
o On pace to achieve the ongoing target – the company’s current
progress is in line with achieving their target
o Not on pace to achieve the ongoing target – the company’s
current progress is not in line with achieving their target
o Lack of data, status not determinable (ongoing target) – the
company’s target is an ongoing target but there is no sufficient
evidence on their progress on the target
o Exceeded the set target – the company has achieved and
exceeded their target (went beyond their set target)
o Achieved the set target – the company has achieved their target
Did not achieve the set target – the company did not reach their
target
o Lack of data, status not determinable (historical target) – the
company’s target is an old/historical target but there is no
sufficient evidence on their progress on the target
Industry Guideline
- Sector: Utilities
China A
Practices – Operations
Programs to reduce toxic emissions and waste in core operations
• Definition: This data point refers to the initiatives/efforts of the company on
reducing toxic emissions and waste in their operations.
(a) Programs to reduce toxic emissions and waste across all operations
(b) Programs to reduce toxic emissions and waste at selected operations
(c) General statements to reduce toxic emissions and waste
(e) No evidence
• Keyword(s):
Toxic emission, waste, environmental, environment
- Scoring:
o Programs to reduce toxic emissions and waste across all
operations – company has efforts/initiatives/programs on
reducing toxic emissions/waste for all their operations
o Programs to reduce toxic emissions and waste at selected
operations – company has efforts/initiatives/programs on
reducing toxic emissions/waste for several of their operations
(either the company listed down the sites or mentioned the
specific names of their operations)
o General statements to reduce toxic emissions and waste – the
company only mentioned that they have
programs/efforts/initiatives to reduce toxic emissions/waste,
but no specific details/scope mentioned
norms – only used for China A defaults for certain China A
issuers
Industry Guideline
- Sub-Industry/Sector: Pharmaceuticals and Biotechnology; Oil & Gas
sector
- Specific Guidance: for companies that have the majority of their
operations in Developed Markets in case of no disclosures.
- Scoring: General statements to reduce toxic emissions and waste
- Sector: Utilities
- Scoring:
o Programs to reduce toxic emissions and waste across all

operations or Programs to reduce toxic emissions and
waste at selected operations – this can be score if the
company disclose formal quantitative targets. Chose the
better options on all operation or selected operations.
o General statements to reduce toxic emissions and waste –
without the quantitative targets on reducing toxic emissions
and waste, use this score.
- Sector: Pharmaceuticals and Biotechnology
Is the Minimum Practice will remove as a default
- Default Scoring: Minimum practices expected based on domestic scoring?
industry norms
- Note: Default score applied except the pure Chinese traditional
medicine(中成药) manufacturing
- Source:
Technical specification for application and issuance of pollutant
permit Pharmacy industry—Biological pharmaceutical products
manufacturing (HJ 1062—2019)
固定污染源排污许可分类管理名录（2019 年版）
Law of the People's Republic of China on the Prevention and
Control of Environment Pollution Caused by Solid Wastes (2020
Revision) http://www.moj.gov.cn/Department/content/2020-
05/06/592_3248103.html
Measures for Pollutant Discharge Permitting Administration
Order No. 736 of the State Council of China issued in 2020
- Sector: All issuers except Building Products, Construction Machinery & Commented [ACJ126]: Pending to Content Team:
Heavy Trucks, Agricultural & Farm Machinery, Industrial Machinery,
For Electrical Equipment: confirm whether Electrical
Electrical Components & Equipment, Heavy Electrical Equipment, Equipment industry will still have no default scoring
Industrial Gases (initially apply to Multi-Utilities, Tires & Rubber,
biotechnology)
industry norms
- Source:
o For Other Industry
• Law of the People's Republic of China on the
Prevention and Control of Atmospheric Pollution
http://www.npc.gov.cn/npc/xinwen/2015-
Law of the People's Republic of China on the
Prevention and Control of Environment Pollution
Caused by Solid Wastes (2020 Revision)
http://www.moj.gov.cn/Department/content/2020-
05/06/592_3248103.html
Measures for Pollutant Discharge Permitting
Administration
Order No. 736 of the State Council of China issued
in 2020
o For Metals & Mining
• The Supervision System for the Prevention and
Control of Soil pollution in Industrial and Mining
Land, MEE, 2018
http://www.mee.gov.cn/gkml/sthjbgw/sthjbl/2018
05/t20180510_438760.htm
o For Energy sector
• Law of the People's Republic of China on the
Prevention and Control of Atmospheric Pollution
http://www.npc.gov.cn/npc/xinwen/2015-
• Notice on further strengthening the management of
environmental impact assessment in the oil and
gas industry, MEE, 2019
http://www.gov.cn/zhengce/zhengceku/2019-
o For Paper Products
• Guideline for available techniques of pollution
prevention and control for pulp and paper industry (
制浆造纸工业污染防治可行技术指南)
http://www.mee.gov.cn/ywgz/fgbz/bz/bzwb/wrfzj
szc/201801/W020180112322914115491.pdf
- Industries: Industries EXCLUDING Electric utilities, Independent Power

Producers & Energy Traders, Oil & Gas Refining & Marketing, Oil & Gas
Drilling, Oil & Gas Equipment Services, Integrated Oil & Gas, Oil & Gas
Exploration & Production, Marine Transport, Coal & Consumable Fuels,
Aluminum, Diversified Metals & Mining, Copper, Gold, Precious Metals
& Minerals, Silver, Steel, Paper Products, Commodity Chemicals,
Diversified Chemicals, Fertilizers & Agricultural Chemicals, Specialty
Chemicals, Construction Materials, Biotechnology, Pharmaceuticals
• Scoring Guidance:
企业) or classified as a priority pollutant discharging entity(重点排污单
位), you can choose General statements to reduce toxic emissions and
waste as default score if no evidence is found
- Source:
o Law on Promotion of Clean Production (清洁生产促进法)

and Regulation on Pollution Discharge Administration（排
污许可证管理条例）
o 许可信息公开 (mee.gov.cn)
Executive body responsible for company's environmental management

strategy and performance
• Definition: This data point refers to the management/team/committee/officer
responsible on environmental issues/strategy/performance of the company.
(e) No evidence
• Keyword(s):
Environment, Environmental, Environmental team, Environment and Safety
team, E&S team, Environment & Safety team, Environmental officer,
Environment and Safety officer, E&S officer, Environment & Safety officer,
Risk officer, CSR team, CSR committee, Sustainability committee,
Sustainability officer, CEO, Chief Executive Officer, CSO, Chief
Sustainability Officer
- This data point MUST ALWAYS be the same score and source with the
data point of the same name under Water Stress KI (if Water Stress KI
is present in the issuer)
- Refrain from using CDP Water disclosures for this data point since the
information within the document is supposed to specifically pertain to
water-related oversights and the data point is asking for environmental
oversight
given when there is clear evidence of their involvement in managing or
being directly responsible on the company’s Environmental-related
issues/performance/strategies (not just based on a mere mention of
board members or executive officers).
- Scoring:
o Board-level committee – score if the committee involving the
board of directors/a board committee is responsible for
Environmental-related issues/ performance/ strategies of the
company
o C-suite or Executive committee – score if a committee

involving the C-suite executives committee or any C-suite
executive (those with Chief titles) is responsible for
Environmental-related issues/ performance/ strategies of the
company
• There are some cases wherein the disclosure
mentions "Chief" officer (ex. Chief Pollution Control
Officer) but cannot verify if the officer is indeed a C-
suite member, we score this as Special task force.
o Special task force or risk officer – score if a dedicated H&S
team or risk officer is responsible for Environmental-related
issues/performance/strategies of the company (not the
CSR/Sustainability/ESG team)
o Corporate Social Responsibility/ Sustainability team – score if
the CSR team, ESG team, Sustainability team is responsible for
all ESG/Sustainability/CSR practices of the company (ensure
that Environmental-related issues/performance/strategies are
also included)
- Guidelines for Specific Industry / Market
China A
企业), first verify the scope of such recognition, and reach out to market
experts for scoring guidance
o Some issuers may disclose that they are recognized as
‘Green Factory’ company ( 绿色工厂 ) by the Ministry of
Industry and Information Technology. As according to the
Evaluation Standards for Green Factory, companies are
required to establish a special task at operation site level
and an executive body be responsible for the strategy and
performance. We exercise caution here by choosing Special
task force or risk officer.
o Source: Evaluation Standards for Green Factory
Environmental performance as a factor in executive compensation

• Definition: This data point refers to the presence of variable compensation
(incentive/bonus) offered to executives regarding the company’s
environmental performance.
(a) Reduction in compensation due to declining environmental
performance
(b) Increase in compensation based on improvements in environmental
performance
(c) General reference to environmental performance being factored in
executive compensation without further details
(d) No evidence
• Keyword(s):
compensation, Environmental performance, Environmental incentive,
Environmental performance bonus, Environmental performance incentive,
long-term award, short-term award, long term award, short term award,
ESG criteria, environment criteria, environmental criteria
- This data point must pertain to executive variable
compensation/bonus payouts and not variable compensation/bonus
payouts for employees on environmental performance.
- Analyst may also refer to the Proxy Statement to see details of
executive remuneration on bonuses (check if it includes
Environmental/ESG criteria)
- Scoring:
o Reduction in compensation due to declining environmental
performance – the company’s executives will have
lesser/reduced variable compensation/payout bonus when the
company’s environmental performance is declining based on the
criterion set for the year
o Increase in compensation based on improvements in
environmental performance – the company’s executives will
have higher/increased variable compensation/payout bonus
when the company’s environmental performance is improving
based on the criterion set for the year
o General reference to environmental performance being
factored in executive compensation without further details –
company only stated that the company’s executive variable
compensation/payout bonus depend/is affected by the
company’s environmental performance based on the criterion
set for the year.
o No evidence – no disclosure of executive variable
compensation/bonus payouts
Practices – Fine and Legal Settlements

Year of settlement
• Definition: This data point refers to the year that the environmental
violation/non-conformance/non-compliance on toxic releases/toxic
emissions were settled by the company.
N/A – free text
• Keyword(s):
Non-compliance, Non-conformance, environmental violation,
environmental non-compliance, environmental non-conformance,
environmental penalty, environmental penalties
- Scoring:
o Place the year of settlement of the fines/legal violations that the
company has obtained
Number of incidents of non-compliance with high severity associated with

toxic releases from operations
• Definition: This data point refers to the total number of violations/non-
conformance/non-compliance that the company has obtained on toxic
releases/environmental regulations.
N/A – free text
• Keyword(s):
- Scoring:
o Place the number of the violations/non-compliance on toxic
releases of the company regardless of severity
Value of fines & legal settlements paid for breaching environmental

regulations
• Definition: This data point refers to the (amount) fines/legal settlements paid
by the company on their violation/non-conformance/non-compliance on
environmental regulations for toxic emissions/releases.
N/A – free text
• Keyword(s):
- Scoring:
o Place the value/amount of the fine/legal settlements paid by the
company for violating or non-compliance to environmental
regulations on toxic emissions/releases
Membership / Signatory/ Certification – Recognized

Environmental Certifications
Title of environmental certifications
• Definition: This data point refers to the environmental certifications that the
company has obtained.
N/A – free text
• Keyword(s):
ISO 14001, ISO-14001, ISO14001, environmental certification
- Only add a row if there are new environmental certifications.
- If company had certifications in previous years
o Retain previously published rows
- For published rows with no data (no environmental certifications for
previous year/s)
o Remove the rows. Moving forward, do not add blank or no
evidence rows if there are no certifications.
- Most common certification is the ISO 14001.
- Scoring:
o Place the name of the environmental certification obtained by
the company.
Estimated percentage of core operations certified to the environmental Commented [ACJ127]:

Pending to Content Team:
certification
• Definition: This data point refers to the percentage of the company’s Check whether the datapoint/table is only for China A
Issuers.
operations that are certified to the environmental certification mentioned.
Note: Follow current approach
N/A – free text
• Keyword(s):
ISO 14001, ISO-14001, ISO14001, environmental certification
- Most common certification is the ISO 14001
- Scoring:
o Place the percentage of the company’s operations that are
certified to environmental certifications.
o If percentage is not provided by the company, use:
• [Total # of sites certified/Total # of sites in the
company] * 100
• NOTE: When calculating, ensure that the total
number of sites are provided by the company or
identifiable; do not make assumptions on the Total
# of sites in the company nor on the Total # of sites
certified.
Water Stress
This issue evaluates the extent to which companies may face water shortages
affecting their ability to operate, lost access to markets due to stakeholder water
conflicts, or higher water costs. Scores are based on exposure to water-stressed
basins and water-intensive segments; water management strategy and targets; water
use over time and vs. peers; and controversies.
Operations
Programs to reduce water consumption in core operations
• Definition: This data point refers to the efforts/programs/initiatives of the
company to reduce water consumption within their operations.
(a) Programs to reduce water consumption across all operations
(b) Programs to reduce water consumption at selected operations
(c) General statements on water usage reduction programs
(e) No evidence
• Keyword(s):
Water, water reduction, water consumption, reduction, consumption
- This data point is generally the same as the Strength of water
efficiency measures data point
- Look into the business model of the company first (usually missed out
at times). Some companies (at least for those under Food Products
and Beverages) outsource their production processes (either fully or
specific portion only), and some have vertically integrated models. This
would help the analyst look for relevant information to score this data
point.
- Sample initiatives include (but are not limited to) the following:
o dry cooling, water recirculation, pipe replacements, leak
detection system (other than pipe replacement), water
saving flush systems/low-capacity water tanks/low flow
showers/guest water use reduction programs, technology
use for predictive agriculture, establishment of water
efficient irrigation infrastructure, black/gray water use or
recycling or reuse, rainwater use, third-party industrial water
use, desalination, using drought tolerant and/or resistant
seed varieties, closed-loop systems/processes (which does
not discharge water, rather recirculates it)
- Be mindful that wastewater treatment/wastewater quality

improvement is NOT a water efficiency measure, or a water use
reduction program unless there is evidence that wastewater is recycled
or reused. Water Stress KI talks about water quantity use, NOT quality
of wastewater/effluent to be discharged
- Scoring:
o Programs to reduce water consumption across all
operations – the company has existing
programs/efforts/initiatives on reducing water
usage/consumption on all their operations
o Programs to reduce water consumption at selected
operations – the company has existing
usage/consumption on some of their operations or if they
have not mentioned the scope as “all operations/sites” but
mentioned a specific company operation/site
o General statements on water usage reduction programs –
the company stated that they have
usage/consumption, but the scope was not specified, and
no further details were mentioned
norms – not being used. Please do not use this score unless
the issuer is a China A issuer (see China A Default Scoring)
China A
- Industry: All sub industries EXCEPT Hotels, Resorts & Cruise Lines and Commented [ACJ128]: @Lo, Riza Anne
Tobacco
Is the Minimum Practice will be remove as a default
- Default Scoring: Minimum practices expected based on domestic scoring?
industry norms as default if there is no evidence
- Source:
Circular of the Ministry of Water Resources and the National
Development and Reform Commission on Issuing the Action Plan for
Synchronous Control over the Total Amount and Intensity of Water
Consumption in the 13th Five-Year Period
http://www.gov.cn/gongbao/content/2019/content_5419221.htm
- Scoring Guidance: Commented [ACJ129]: New China A guidelines

o Water saving enterprises: Enterprises that adopt advanced
and applicable management measures and water-saving
technologies and whose water efficiency has reached the

advanced level of the same industry in China after
evaluation
• To search if the issuer is a water-saving enterprise
or not, please search “节水型企业” in AR+CSR+SR,
or google search the company name+节水型企业
o If the issuer is certified as “water-saving enterprise”
(National and Province-level ONLY), it is considered to have
the default score of General statements on water usage
reduction programs
- Source: 在线预览|GB/T 7119-2018 (gb688.cn)
Executive body responsible for company's environmental management

strategy and performance
• Definition: This data point refers to the
management/team/committee/officer responsible on environmental
issues/strategy/performance of the company.
(e) No evidence
• Keyword(s):
Sustainability Officer, ISO 14001, ISO14001
- May also be found in E&S policy
- The presence of ISO 14001 Environmental Management Systems
certification could indicate the presence of a body for environmental
management. Few of its requirements include environmental audits
and environmental performance evaluation.
o Further reference: https://www.epa.gov/ems/frequent-
questions-about-environmental-managment-systems,
https://www.british-assessment.co.uk/insights/what-are-
the-iso-14001-requirements/
- If Toxic Emissions & Waste KI is present, the data point MUST ALWAYS
have same score and source.
- Refrain from using CDP Water disclosures for this data point since the
information within the document is supposed to specifically pertain to
water-related oversights and the data point is asking for environmental
oversight
- Scoring:
o Board-level committee – score if the committee involving
the board of directors/a board committee is responsible for
Environmental-related issues/performance/strategies of
the company
o C-suite or Executive committee – Score if there is clear
evidence involvement in managing or being directly
responsible on the company’s Environmental-related
issues/performance/strategies (not just based on a mere
mention of board members or executive officers, it should
be with Chief titles).
o Special task force or risk officer – score if a dedicated H&S
team or risk officer is responsible for Environmental-related
issues/performance/strategies of the company (not the
CSR/Sustainability/ESG team)
o Corporate Social Responsibility/ Sustainability team –
score if the CSR team, ESG team, Sustainability team is
responsible for all ESG/Sustainability/CSR practices of the
company (ensure that Environmental-related
issues/performance/strategies are also included); use this
as minimum score if company is CERTIFIED to ISO 14001,
BUT there is no clear disclosure the company has an
executive body/board/special task force or risk officer
responsible for environmental
issues/performance/strategies. (Source: ISO 14001 Clause
5.1 on Leadership and Commitment)
China A

evaluation
(National and Province-level ONLY), it is considered to
have the default score of Special task force or risk officer
Programs to regularly monitor and measure water risk at company's

operations
• Definition: This data point refers to company initiatives/programs on
monitoring, assessing, measuring water risk in their operations.
(a) Risk assessment covers all operations
(b) Risk assessment covers selected operations
(c) Risk assessment under development
(e) No evidence
• Keyword(s):
Water, water risk, water-stressed, water stressed, risk assessment, WRI
Aqueduct Tool
- Look out whether the company discloses on where they source water
from for their operations, and whether they assess what is the potential
impact (environmental, financial, social). Water audits, compliance,
monitoring the usage of water etc.
- Merely measuring or monitoring water usage (i.e., for FY 2020, the
company used 1 million m3 of water) is NOT tantamount to water-risk
assessment
- Look out for Risk Assessment section for water risks
- Look of for use of WRI Aqueduct Tool. If company mentions the use,
they generally are assessing water risks
o Scope depends on the company’s explicit disclosure on
which sites undergone water risk assessment
- CDP Water may also have information on water risk of the company
o However, investigate the scope of CDP Water for accurate

attribution. Some companies have decentralized
EMS/environmental reporting schemes.
- Scoring:
o Risk assessment covers all operations – the company’s
ongoing/current risk assessment applies to all the company
operations/sites
o Risk assessment covers selected operations – the
company’s ongoing/current risk assessment applies to
some of the company operations/sites or if they have not
mentioned the scope as “all operations/sites” but
mentioned a specific company operation/site; if scope
ambiguous in CDP Water but there is disclosure available
o Risk assessment under development – the company is
planning/developing a risk assessment in their operations
to be implemented in the next year or in the future (either on
all operations, some of their operations, or if scope was not
mentioned)
norms – not being used. Please do not use this score even
if the issuer is a China A issuer
Disclosure to CDP Water

• Definition: This data point provides information if the company has a
disclosure on CDP Water.
(a) Yes
(b) No evidence
• Keyword(s):
CDP, CDP Water
- Check cdp.net on the company’s disclosure on CDP water. Ensure that
it is on CDP Water and not on CDP Carbon, etc.
- Those CDP reports that are not accessible are non-submissions
- If the company is a participant of CDP in the CDP website and their last
CDP water report was that of the previous year but for the current
updating year, they stopped participating. Retain “Yes” score but
change to “No Evidence” if there is no submission for 3 years straight
- Scoring:
o Yes – the company has an accessible

disclosure/submission of their data in CDP Water.
o No evidence – the company has no disclosure/did not
submit their data in CDP Water or the company is not found
in the CDP Water database.
Strength of water efficiency measures

• Definition: This data point provides information on water efficiency or
conservation measures/efforts of the company.
(a) Uses best available technologies/processes to conserve water across
all relevant operations
(b) Uses best available technologies/processes to conserve water across
selected operations
(c) Investigating best available technologies/processes to conserve water
(d) No evidence
• Keyword(s):
Efficiency, water efficiency, water conservation, conserve water, conserve,
water reduction, reduce water, water usage, water use, water consumption,
consume water, consumption
- This data point is generally the same as the Programs to reduce water
consumption in core operations data point
specific guidance.
- Sample initiatives include (but are not limited to) the following:
o dry cooling, water recirculation, pipe replacements, leakage
reduction program (other than pipe replacement), water
saving flush systems/low-capacity water tanks/low flow
showers/guest water use reduction programs, technology
use for predictive agriculture, establishment of water
efficient irrigation infrastructure, black/gray water use or
recycling or reuse, rainwater use, third-party industrial water
use, desalination
- Be mindful that wastewater treatment/wastewater quality
improvement is NOT a water efficiency measure or a water use
reduction program unless there is evidence that wastewater is recycled
or reused. Water Stress KI talks about water quantity use, not quality of
wastewater/effluent to be discharged.
- Scoring:
Uses best available technologies/processes to conserve

o
water across all relevant operations – the company has
processes/technologies in place to conserve water across
all their operations/sites
o Uses best available technologies/processes to conserve
water across selected operations – the company has
processes/technologies in place to conserve water across
all their operations/sites or if they have not mentioned the
scope as all operations but mentioned a specific company
operation/site
o Investigating best available technologies/processes to
conserve water – the company is planning/developing
technologies/processes to conserve water in their
operations to be implemented in the next year or in the
future (either on all operations, some of their operations, or
if scope was not mentioned)
China A
evaluation
the default score of Investigating best available
technologies/processes to conserve water
Utilities sector
- See below scores that should correspond with the scores found in the
Programs to reduce water consumption in core operations datapoint
water across all relevant operations – Should correspond
with “Programs to reduce water consumption across all
operations”

water across selected operations – Should correspond
with “Programs to reduce water consumption in selected
operations”
o Investigating best available technologies/processes to
conserve water – Should correspond with “General
statements on water usage reduction programs”
Targets
Evidence of ongoing/ future target(s) to reduce water consumption/
withdrawal
• Definition: This data point refers to any evidence of current and/or future
targets on reducing water consumption/withdrawal in the company’s
operations.
(a) Yes
(b) Qualitative evidence
(d) No evidence
• Keyword(s):
Water target, water targets, water reduction, reduce water, reduce
consumption, reduce withdrawal, water reduction target, reduction target,
target, water withdrawal, withdrawal, withdrawal target, withdrawal targets,
consumption, consumption target, withdrawal reduction target, withdrawal
reduction targets, consumption reduction target, reduce withdrawal,
reduce consumption
- Scoring Yes for this data point will require the analyst to fill in the
Targets table (see Practices – Targets – Water Consumption/
Withdrawal Targets section of this manual)
- The quantitative target MUST BE ONGOING to have "Yes" as a score. If
target is outdated and there is no evidence of any active/ongoing
targets we score “No evidence”.
- Scoring:
o Yes – company has targets (quantitative); For the target to
be quantitative, they should have at least the following:
Baseline Year, Baseline Year Value, Target Year, and Target
Year Value, and a quantitative description of the target
should be present (e.g., 10% reduction of water withdrawn
from groundwater by 2030 compared to 2015 baseline).
Otherwise, the target will fall under qualitative.
Qualitative evidence – company only mentioned qualitative

o
targets (no specific numerical targets mentioned); general
statements on water withdrawal/consumption reduction
will suffice for this data point
norms – not being used. Please do not use this score unless
the issuer is a China A issuer (see China A Default Scoring)
o No evidence – no targets
China A
- Sub-Industry - All
industry norms as default if there is no evidence
- Source:
National target applicable: strict control of water usage - a
volume cap established for 2030
Notice of industrial water quotas for water-intensive
industry issued by the Ministry of Water Resources in 2019
and 2020 water-intensive Industry water-use quota
adjustment by each province
http://www.mwr.gov.cn/zwgk/gknr/202005/t20200527_1
441199.html
https://www.miit.gov.cn/jgsj/jns/zyjy/art/2021/art_ad621
6d6f2e6489f94ff80e4d1843286.html
https://www.miit.gov.cn/jgsj/jns/zyjy/art/2020/art_47210
918f8384cb0bcf988a08ebec384.html
Products & Services

Programs to measure water footprint of its products
• Definition: This data point refers to programs/initiatives/efforts of the
company on measuring water-foot print of its products. Water foot printing
is accounting for water use for each product and not an overall water
intensity of the organization.
(a) Water foot-printing for all products
(b) Water foot-printing for selected products
(c) No evidence
• Keyword(s):
Water, water footprint, water footprint
- Not scored if Water Stress is a Non-Weighted Key Issue
specific guidance.
- This data point is pertaining to company products (products that they
offer to customers/consumers) and should include water use in the
supply chain as well (as most water usage in a product is in the supply
chain, and not necessarily just in the company's manufacturing sites)
- Water footprint sample
o The production of one kilogram of beef requires
approximately 15 thousand liters of water (93% green, 4%
blue, 3% grey water footprint). The water footprint of a 150-
gramme soy burger produced in the Netherlands is about
160 liters. (https://waterfootprint.org/en/water-
footprint/what-is-water-footprint/)
o If there is no disclosure along these lines, but only reports a
company-wide (not per product) intensity, do not consider
- Scoring:
o Water foot-printing for all products – the company has
water foot-printing for all relevant company products (i.e.,
those that need water for production such as agricultural
products)
o Water foot-printing for selected products – the company
has water foot-printing for selected company products or if
they have not mentioned the scope as all products but
mentioned a few specific product/s (general scope)

China A
Industry Guidelines
- Sector / Industry / Sub-Industry: Utilities, Chemicals industries
(Diversified Chemicals, Specialty Chemicals, Commodity Chemicals,
Fertilizers, Industrial Gases GICS SUB INDUSTRIES), Metals & Mining and
Steel industries, Hotels, Restaurants & Leisure industries
- Specific Guidelines: leave at No Value
Supply Chain
Programs to reduce water usage in its supply chain
• Definition: This data point refers to programs/efforts/initiatives of the
company to reduce water usage among the company’s suppliers and/or
within its supply chain.
(a) Programs to reduce water consumptions across all suppliers
(b) Programs to reduce water consumptions for selected suppliers
(c) General statements on water consumption reduction programs for
suppliers
(d) No evidence
• Keyword(s):
Water, water reduction, water consumption, reduction, consumption,
supplier water, supply chain water, agricultural supply chain
- Look into CDP Water Reports, if available. Such offers specific details
on supply chain measures (if there are any)
- Scoring:
o Programs to reduce water consumptions across all
suppliers – the company has programs/efforts/initiatives
on reducing water usage/consumption of all their suppliers
across their supply chain
o Programs to reduce water consumptions for selected
suppliers – the company has programs/efforts/initiatives
on reducing water usage/consumption on selected/some
suppliers across their supply chain or if they have not
mentioned the scope as all suppliers but mentioned only a
few specific supplier/s
o General statements on water consumption reduction
programs for suppliers – the company has
usage/consumption for their suppliers/supply chain, but the
scope was not specified, and no further details were
mentioned

Industry Guidelines
- Sector / Industry / Sub-Industry: Utilities, Chemicals industries
Steel industries, and Paper Products Sub Industry
o Specific Guidelines: leave at No Value
- Sector / Industry / Sub-Industry: Food Products and Beverages
companies that outsource their production processes from third party
contractors
o Specific Guidelines:
• Datapoint pertains to water usage in the company's
agricultural supply chain. Water-saving programs
with such third-party contractors do not constitute
merit under Water Stress - Supply Chain data points.
In these cases, it must be clear that water-saving
programs extend to the agricultural supply chain."
Water reduction target for supply chain
• Definition: This data point refers to the company’s set target on water
reduction for its suppliers and/or supply chain.
(a) Quantitative target for all suppliers
(b) Quantitative target for selected suppliers
(c) No Evidence
• Keyword(s):
Supplier water, water supply chain, Water target, water targets, water
reduction, reduce water, reduce consumption, reduce withdrawal, water
reduction target, reduction target, target, water withdrawal, withdrawal,
withdrawal target, withdrawal targets, consumption, consumption target,
withdrawal reduction target, withdrawal reduction targets, consumption
reduction target, reduce withdrawal, reduce consumption
specific guidance.
- Consider only EXPLICIT disclosures for QUANTITATIVE targets
specifically for suppliers
- Scoring:
o Quantitative target for all suppliers – company sets a
quantitative target on reducing water usage/consumption
that all suppliers across their supply chain should adhere to
o Quantitative target for selected suppliers – company sets
a quantitative target on reducing water usage/consumption
that all suppliers across their supply chain should follow or
if they have not mentioned the scope as all suppliers but

mentioned only a few specific supplier/s
o No Evidence – no disclosure or the company mentions they
have a target for suppliers in their supply chain on reducing
their water usage/consumption, but target is not
quantitative, scope of target is not determinable, or no
further details were mentioned.
China A
Industry Guidelines
- Sector / Industry / Sub-Industry: Utilities sector, Chemicals industries
Steel industries, Hotels, Restaurants & Leisure industries, and Paper
Products Sub Industry
o Specific Guidelines: leave at No Value
- Sector / Industry / Sub-Industry: Food Products and Beverages
companies that outsource their production processes from third party
contractors
o Specific Guidelines:
• Datapoint pertains to water usage in the company's
agricultural supply chain. Water-saving programs
with such third-party contractors do not constitute
merit under Water Stress - Supply Chain data points.
In these cases, it must be clear that water-saving
programs extend to the agricultural supply chain."
Governance and Strategy

Percentage of water consumption from alternative water sources (i.e. grey
water, rainwater, sewage)
• Definition: This data point records the percentage of water consumption
from alternative water sources like grey water, rainwater, sewage, etc.
N/A = free text
• Keyword(s):
Non-freshwater, other water, Others, Seawater, Brackish water, Wastewater
from another organization, Industrial water, Rainwater, Non-potable,
Produced, Reclaimed/Recycled water, Grey water, Processed water, Mine
dewatering, Brackish surface water/Seawater, Produced/Entrained Water
- This data point is pertaining to water withdrawal, not water
consumption. Use water withdrawal data.
- This data point should generally have the same value as the latest value
in Alternative Water Use (seawater, brackish water, rainwater, gray
water) (%) data point
- Scoring:
o Place the percentage of alternative/other water withdrawal
of the company
o If percentage is not disclosed but data point can be
calculated, calculate the percentage of alternative water
withdrawal sources
• (Total Water Withdrawal from Alternative Water
Sources/Total Water Usage from all sources) *100
o If percentage cannot be calculated, leave blank
- NOT TO BE SCORED if Water Stress is a Non-Weighted Key Issue
Evidence of Using Alternative Water Sources

• Definition: This data point refers to any evidence of company using
alternative water sources.
(a) Yes
(b) No
• Keyword(s):
- Condition 1: Automatically 'Yes' if Percentage of water consumption
from alternative water sources (i.e., grey water, rainwater, sewage) is
scored (greater than 0).
- Condition 2: Data point is Yes but Percentage of water consumption
from alternative water sources (i.e. grey water, rainwater, sewage) can
be blank.
o Example: Company has a statement that the usage of an
alternative but actual numbers were not disclosed
- Scoring:
o Yes – the company has a disclosure that they use
alternative water sources (regardless of it is disclosed as
quantitative data or a statement).
No – no evidence or the company does not use alternative

o
water sources for their operations
China A
evaluation
the default score of Yes
Water recirculation/recycling rate

• Definition: This data point refers to the company's water
recirculation/recycling rate.
N/A = free text
• Keyword(s):
Water recycled, water recirculation, water recycling rate, water recirculation
rate, water reused
- This data point should generally have the same value as the latest value
in Water Recycling Rate (%) data point
- Scoring:
o Place the percentage of the water that the company has
recycled/reused (water that was originally not a
recycled/reused water but was recycled/reused by the
company in their operation)
o The value should be the same number as with the latest
value (latest year) in the Water Recycling Rate (%) datapoint
found in Performance – Water Withdrawal Performance
Table
Refrain from calculating this data point as much as possible

o
unless it has been clear that the data is pertaining to the
water the company has reused in their operation
• If there is clear data on total water recycled and total
water withdrawal, calculate using: [(Total Water
Recycled/Total Water Withdrawal) * 100] to get the
percentage
o Do not confuse this with the water the company has
withdrawn/abstracted/taken from recycled/reused water
sources
o If recycling/recirculation rate cannot be found/calculated,
leave blank
China A
- Specific Guidelines: This is a China A data point and is only scored when
the issuer is a China A issuer AND Water Stress is a Company-
Specific/Industry-Specific Key Issue
Governance and Strategy - Executive body responsible for

water management strategy and performance
Responsibility for water management strategy and performance is with
non-executive or non-committee level task force
• Definition: This data point refers to presence of a non-executive or non-
committee level task force responsible for water management strategy
and performance of the company
(a) Yes
(b) No
(c) Not Disclosed
• Keyword(s):
Sustainability Officer, Water
- This data point is different from “Executive body responsible for

company's environmental management strategy and performance” data
point which asks for the person/team/executive/board
committee/group/officer responsible on the company’s
environmental-related issues/programs/performance/strategy
- The data point is asking for following conditions
o This is specifically for the company’s water management
strategy/performance. If water was not explicitly
mentioned, it is not considered
o The person/team/group/officer should NOT an
executive/board committee or that of a task force with a
similar level
- Scoring:
o Yes – the company has a specific non-executive/non-
committee level task force specifically for water
management strategy/performance of the company
o No – the company’s water management
strategy/performance falls under an executive/executive
management, board committee, or that of a task force with
a similar level with executives/board
o Not Disclosed – no evidence
Other
• Definition: This data point refers to name of the non-executive or non-
committee level task force responsible for the water management strategy
and performance of the company
N/A = free text
• Keyword(s):
Sustainability Officer, Water
- Scoring:
o This data point is filled in when “Responsibility for water
management strategy and performance is with non-
executive or non-committee level task force” data point is

scored Yes
o Place the specific person/team/group/officer responsible
for the water management strategy/performance of the
company, otherwise, leave blank
Targets - Water Consumption/ Withdrawal Targets

IMPORANT NOTE on TARGETS: Ensure that targets are on their water
withdrawal/consumption targets. Historical and current/ongoing targets are all
valid for this data point
- Freshwater withdrawal/consumption targets are valid
- Water recycling targets are NOT valid
- Targets on reducing effluent/wastewater discharge are NOT valid
Baseline Year
• Definition: This data point refers to the year where the company’s water
withdrawal/consumption reduction target will be compared to.
N/A – free text
• Keyword(s):
reduce consumption
- Please be guided on IMPORANT NOTE on TARGETS
- Scoring:
o Place the year of the value where the company’s Water
Withdrawal/Consumption target will be compared to
(baseline year)
o Leave blank if data point cannot be scored/no disclosure
from the company
Baseline Year Value

• Definition: This data point refers to the value where the company’s water
withdrawal/consumption reduction target will be compared to.
N/A – free text

• Keyword(s):
reduce consumption
- Scoring:
o Place the value where the company’s Water
Withdrawal/Consumption target will be compared to
(baseline value)
from the company
Implementation Year
• Definition: N/A
N/A – free text
• Keyword(s):
N/A
Scoring
Implementation Year Value

• Definition: N/A
N/A – free text
• Keyword(s):
N/A
Scoring
Target Year
• Definition: This data point refers to the year when the company aims to
achieve their water withdrawal/consumption reduction target.
N/A – free text
• Keyword(s):
reduce consumption
- Ensure that targets are on their water withdrawal/consumption targets.
o Freshwater withdrawal/consumption targets are valid
o Water recycling targets are NOT valid
o Targets on reducing effluent/wastewater discharge are
NOT valid
- Scoring:
o Place the year of the company’s Water
Withdrawal/Consumption target is aimed to be achieved
from the company
Target Category
• Definition: This data point refers to the category of the company’s water
withdrawal/consumption reduction target.
Water Consumption Reduction – Absolute
• Water Consumption Reduction – Intensity
• Water Withdrawal Reduction – Absolute
• Water Withdrawal Reduction – Intensity
• Other
• Keyword(s):
reduce consumption

- Absolute vs Intensity
o Absolute = actual value of water withdrawal/consumption
data
o Intensity = water withdrawal/consumption data per person,
USD, person, etc. (examples: m3/production, gallons per
USD, ML/production, etc.)
- Scoring:
o Water Consumption Reduction – Absolute – company’s
target is on their actual water consumption values
o Water Consumption Reduction – Intensity – company’s
target is on the water consumption intensity
o Water Withdrawal Reduction – Absolute – company’s
target is on their actual water withdrawal values
o Water Withdrawal Reduction – Intensity – company’s
target is on water withdrawal intensity
o Other – company’s quantitative target is available, but the
category does not fall within scoring dropdowns a to d.
However, most (or all) of targets fall within the a to d
categories
Target Description
• Definition: This data point refers to the details on the water
withdrawal/consumption reduction target.
N/A – free text
• Keyword(s):
reduce consumption
- Scoring:
o Place the details/description of the company’s target
Industry Guidelines
- Sector: Utilities sector
o Targets on technological advances are valid. Examples are

installing scrubbers, precipitators, flue gas cleaners, etc.
Target Year Value

• Definition: This data point refers to the end goal value of the company’s
water withdrawal/consumption reduction target.
N/A – free text
• Keyword(s):
reduce consumption
- Scoring:
o Place the value of the company’s Water
Withdrawal/Consumption target
from the company

• Definition: This data point refers to the percentage of reduction that the
company’s water withdrawal/consumption reduction target aims to
achieve.
N/A – free text
• Keyword(s):
reduce consumption
- Scoring:
o Place the targeted percentage reduction of the company’s

Water Withdrawal/Consumption.
o This formula may be used if the data is available:
• [(Baseline Year Value - Target Year Value)/Baseline
Year Value] *100.
▪ Example: if company's Water Withdrawal for
FY 2019 is 150,000 m3 and they want to
reduce it to 90,000 m3 by 2025, the target
reduction is going to be [(150,000-
90,000)/150,000] *100 = 40%
o Leave blank if data point cannot be calculated/no
disclosure from the company
Target Scope
• Definition: This data point refers to scope of the company’s operation who
will participate in the water withdrawal/consumption reduction.
(d) Targets covers all relevant segments
(e) Targets covers selected segments
(f) Scope not determinable
• Keyword(s):
reduce consumption
on the company’s “Scope of the Report” or “About the Report” at the
start of their reports, or on the introductory paragraph of their
- Scoring:
o Targets covers all relevant segments – target is for all the
company’s operations/sites
o Targets covers selected segments – target is only for a few
operations/sites of the company or if the company
mentioned the sites/operations the target is applied to
o Scope not determinable – no mention on the scope of the

targets
Reduction Target – Estimation Key

percentage of reduction of their water withdrawal/consumption reduction
target.
(c) Reported
(d) Estimated
• Keyword(s):
reduce consumption
- Always scored if Target Reduction (%) data point is scored
- Scoring:
o Reported – percentage reduction target was disclosed by
the company
o Estimated – percentage reduction target was manually
calculated and not disclosed by the company
Per Year Reduction Target – Estimation Details

• Definition: This data point refers to the details on the company’s
percentage of reduction that their water withdrawal/consumption
reduction target aims to achieve.
N/A – free text
• Keyword(s):
reduce consumption

- Scoring:
o Place the details on the percentage reduction of the
company’s Water Withdrawal/Consumption
o Leave blank if there are no details provided by the company
Progress Against Target (%)

• Definition: This data point refers to the progress of the company (in %) on
their water withdrawal/consumption reduction target.
N/A – free text
• Keyword(s):
reduce consumption
- Scoring:
o Place the progress of the company on their Water
Withdrawal/Consumption target (in percentage)
o Leave blank if there is no disclosure provided by the
company
Status on Achieving Target

• Definition: This data point refers to the progress of the company on their
water withdrawal/consumption reduction target.
(h) On pace to achieve the ongoing target
(i) Not on pace to achieve the ongoing target
(j) Lack of data, status not determinable (ongoing target)
(k) Exceeded the set target
(l) Achieved the set target
(m) Did not achieve the set target
(n) Lack of data, status not determinable (historical target)
• Keyword(s):

reduce consumption
- If it is difficult to determine whether the company is on pace or not on
pace in the target, you may use any of the formulas below
o [(Target Year Value - Current Value)/Remaining Years]
o [(Baseline Year Value - Target Year Value)/Baseline Year
Value]
o If the answer seems to achieve or exceed the target, then
it's on pace. If it falls short, then it's not on pace.
- Scoring:
o On pace to achieve the ongoing target – the company’s
current progress is in line with achieving their target
o Not on pace to achieve the ongoing target – the company’s
current progress is not in line with achieving their target
o Lack of data, status not determinable (ongoing target) –
the company’s target is an ongoing target but there is no
sufficient evidence on their progress on the target
o Exceeded the set target – the company has achieved and
exceeded their target (went beyond their set target)
o Achieved the set target – the company has achieved their
target
o Did not achieve the set target – the company did not reach
their target
o Lack of data, status not determinable (historical target) –
the company’s target is an old/historical target but there is
no sufficient evidence on their progress on the target
Performance – Water Intensity Reported

Do not add rows if Water Stress is a Non-Weighted Key Issue (Only score when
Water Stress is a weighted Key Issue (Company-Specific or Industry-Specific)
Year
• Definition: This data point refers to the year of the company’s water
intensity data
N/A = free text
• Keyword(s):
Water intensity, intensity
- Scoring:
o Place the year of the Water Intensity data of the company
o Avoid duplication of entered year
Intensity Reported
• Definition: This data point refers to the value of their water intensity.
N/A = free text
• Keyword(s):
Utilities sector keywords: leakage, rate, leak, non-revenue water, NRW,
abstraction, distribution input, input, distribution loss rate, loss rate
- Intensity pertains to water withdrawal/consumption data per person,
USD, person, etc. (examples: m3/production, gallons per USD,
ML/production, etc.)
- Scoring:
o Place the value of the water intensity data of the company
o Can be freshwater withdrawal intensity, freshwater
consumption intensity, or total water intensity of the
company (whichever is available)
• If all are available, use total intensity for this data
point but indicate the other freshwater intensity data
under the respective freshwater intensity data
points (Freshwater Withdrawal Intensity – Reported
and Freshwater Consumption Intensity – Reported)
Industry Guidelines
o Intensity Reported is computed as freshwater use
(excluding hydro) divided by the MWh generation from coal
+ gas + liquid fuel + nuclear. Hence, units should be m3
freshwater/MWh
Intensity Reported Details

• Definition: This data point refers to the unit that was used in their water
intensity data and other additional details
N/A = free text
• Keyword(s):
- Scoring:
o Place the unit of the water intensity of the company or the
water intensity data description of the company
Performance – Water Withdrawal Performance

• IMPORTANT: Check the additional guidance for water
withdrawal/consumption.
• Different terms are used for water withdrawal and consumption including
"water use", "water usage", "water consumption", "water intake", "water
abstraction", "water withdrawal".
Year
• Definition: This data point refers to the year of all the available data placed
in the Water Withdrawal table
N/A = free text
• Keyword(s):
Water withdrawal, water abstraction, water intake, withdrawal, abstraction,
intake, abstracted, water input, water withdrawn
- Scoring:
o Place the reporting year of the water data of the company
Scope of Reported Water Withdrawal Data

• Definition: This data point refers to the scope of the company’s water
withdrawal data is pertaining to.
(a) Covers all relevant operations or product segments
(b) Covers selected operations or product segments
• Keyword(s):
on the company’s “Scope of the Report” or “About the Report “at the
- Scoring:
o Covers all relevant operations or product segments – water
withdrawal data is from all company operations/sites
o Covers selected operations or product segments – water
withdrawal data are on some of the company’s
operations/sites or if they have not mentioned the scope as
“all operations/sites” but mentioned a specific company
operation/site
o Scope not determinable – the scope of the water
withdrawal data is not identifiable/not provided by the
company or if the company does not have any water data
that can be placed on the water consumption table (no
disclosure)
Freshwater Withdrawal – Reported

• Definition: This data point refers to the value of company’s freshwater
withdrawal. Water Withdrawal generally refers to the water that the
company has taken from/abstracted from the environment/external
sources
N/A = free text
• Keyword(s):
intake, abstracted, water input, water withdrawn, freshwater, fresh water,
surface water, tap water, municipal water, groundwater (renewable and
non-renewable), mine water (non-brackish), potable water, utility, third-
party, quarry water, entrained water, Fresh surface water, including
rainwater, water from wetlands, rivers, and lakes, Groundwater –

renewable, Groundwater – non-renewable, Third party sources
- IMPORTANT: Use the Conversion Rule in Additional Guidance below
- Common terms include "withdrawal", "abstraction", "intake"
- Scoring:
o Place the total amount of the company’s freshwater
withdrawal. Always indicate in the Internal Notes any data
provided by the company on the data point (e.g., why the
data was placed or why not the data was placed in Capture,
calculations, explanations on any data/disclosure, etc.)
o If total freshwater withdrawal is not provided but the
breakdown of water withdrawal sources was disclosed, add
all the identified freshwater sources.
o If no freshwater withdrawal was identified in the water
withdrawal data or if the company did not explicitly provide
information on the freshwater withdrawal, leave this data
point blank but provide Internal Notes (see General
Procedure section of this data point for specific cases)
o For CDP disclosures, navigate to W1.2h of the company’s
CDP report and add the freshwater sources
• Standard unit in all CDP reports are in megaliters,
convert to m3 using the Conversion Rule
Industry Guidelines
o Freshwater withdrawal will only include water withdrawal
for use by coal, liquid fuel, nuclear, and biomass plants for
operations, process water, and cooling.
o If there is data on withdrawal for use in hydro, solar, and
wind plants, exclude for freshwater withdrawal and instead
it will be included in the Total Withdrawal. [Note: usually,
there is no withdrawal data for use in solar and wind,
however, it will also be placed under Total Withdrawal only
like hydro]
Freshwater Withdrawal Intensity – Reported

• Definition: This data point refers to the value of the freshwater withdrawal
intensity of the company
N/A = free text
• Keyword(s):
Freshwater withdrawal intensity, Freshwater, fresh water, Surface water,
tap water, municipal water, groundwater (renewable and non-renewable),
mine water (non-brackish), potable water, utility, third-party, quarry water,
entrained water, Fresh surface water, including rainwater, water from
wetlands, rivers, and lakes, Groundwater – renewable, Groundwater – non-
renewable, Third party sources
- This is only for the company’s freshwater withdrawal intensity. If it is
not clear that the data is pertaining to freshwater withdrawal intensity,
do not consider
- Scoring:
o Place the value of the freshwater withdrawal intensity data
of the company
o Always indicate in the Internal Notes any data provided by the
company on the data point (e.g., why the data was placed or
why not the data was placed in Capture, explanations on any
data/disclosure, etc.)
o Leave data point blank if there is no disclosure provided by
the company
Industry Guidelines
o For power producers
• Only include water withdrawal from coal, gas, liquid
fuel, nuclear plants in the denominator. Numerator
is MWh from the same plants
• EXCLUDE: hydro and other Renewable Energy
o Be careful with this DP as most issuers report the entire
water intake. To be more sure, you might go to CDP section
W5 (facility-level water accounting) as the type of plants are
specified.
o For Water Utilities:
• We report leakage rate in MLD. You might need to
scrutinize documents outside the SR or AR for this
in most UK and US companies.
Freshwater Withdrawal Intensity – Reported Unit

• Definition: This data point refers to the unit of the freshwater withdrawal
N/A = free text
• Keyword(s):
Freshwater withdrawal intensity, Freshwater, fresh water, Surface water,
- This is only for the company’s freshwater withdrawal intensity. If it is
not clear that the data is pertaining to freshwater withdrawal intensity,
do not consider
- Scoring:
o Place the unit of the freshwater withdrawal intensity of the
company or the freshwater withdrawal intensity data
description of the company
the company
Total Water Withdrawal – Reported

• Definition: This data point refers to the value of company’s total water
withdrawal. Water Withdrawal generally refers to the water that the
sources
N/A = free text
• Keyword(s):
- Must be the sum of all Freshwater and Alternative/Other Water
Withdrawals in Capture
- Scoring:
o Place the total amount of the company’s total water
withdrawal. Always indicate in the Internal Notes any data
provided by the company on the data point (e.g., why the data
was placed or why not the data was placed in Capture,
o If total withdrawal is not provided but the breakdown of
water withdrawal sources was disclosed, add all the
withdrawal data to get the total.
o If total withdrawal data was not provided by the company or
if the company did not explicitly provide that the information
is pertaining to total withdrawal, leave this data point blank
but provide Internal Notes.

• Definition: N/A
N/A = free text
• Keyword(s):
N/A
- Scoring:
o Leave this data point blank
Industry Metric Value Unit

• Definition: N/A
N/A = free text
• Keyword(s):
N/A
- Scoring:
Other Water Withdrawal – Company Reported Value

• Definition: This data point refers to the value of company’s
alternative/other water withdrawal. Water Withdrawal generally refers to
the water that the company has taken from/abstracted from the
environment/external sources
N/A = free text

• Keyword(s):
- Sometimes company discloses a wrong value on their total
alternative/other withdrawal (company might have a different
understanding of alternative/other withdrawals and sometimes
groundwater, which is considered as freshwater in our methodology,
are considered as alternative/other water for them). Manually
calculate the freshwater withdrawal in these cases and indicate in the
"Details" field that values were manually calculated
- On restated data
o If the company has undergone a
divestment/acquisition/merger/restructuring and has
restated its historical other/alternative water withdrawal
based on a change in scope, please do NOT restate
historical values.
o Historical values can be changed ONLY if the company
made an error in the previous year and has reported correct
values with the SAME scope
o If company has restated in their latest report, kindly place in
the Internal Notes the original values that were restated
- Scoring:
o Place the total amount of the company’s other/alternative
water withdrawal. Always indicate in the Internal Notes any
data provided by the company on the data point (e.g., why
the data was placed or why not the data was placed in
Capture, calculations, explanations on any data/disclosure,
etc.)
o If total other/alternative withdrawal is not provided but the
breakdown of water withdrawal sources was disclosed, add
all the identified alternative/other sources.
o If no alternative/other water withdrawal was identified in the
water withdrawal data or if the company did not explicitly
provide information on the alternative/other water
withdrawal, leave this data point blank but provide Internal
Notes
o For CDP disclosures, navigate to W1.2h of the company’s

CDP report and add the freshwater sources
• Standard unit in all CDP reports are in megaliters,
convert to m3 using the Conversion Rule
Other Water Withdrawals – Details

• Definition: This data point refers to additional details of company’s
alternative/other water withdrawal (alternative water breakdown,
calculations, etc.). Water Withdrawal generally refers to the water that the
sources
N/A = free text
• Keyword(s):
- Scoring:
o This is where additional information on Other/Alternative
Water Withdrawal is placed (examples: name of
other/alternative water withdrawals, values, calculations)
Alternative Water Use (seawater, brackish water, rainwater, gray water)

(%)
alternative/other water withdrawal from the company’s total water
withdrawal.
N/A = free text
• Keyword(s):
- SHOULD NOT BE BLANK when Total Water Withdrawal - Reported and
Other Water Withdrawal - Company Reported Value data points are
filled in
- Scoring:
o Place the percentage of water withdrawal that came from
alternative sources. Always indicate in the Internal Notes any
data provided by the company on the data point (e.g., why
the data was placed or why not the data was placed in
Capture, calculations, explanations on any data/disclosure,
etc.)
o If no percentage was provided by the company but Total
Water Withdrawal - Reported and Other Water Withdrawal
- Company Reported Value data points are filled in,
manually calculate the percentage from the values
• Calculation: (Other Water Withdrawal - Company
Reported Value/Total Water Withdrawal - Reported)
*100
the company or value cannot be calculated
Water Recycling Rate (%)

• Definition: This data point refers to the percentage of water that was
recycled/reused by the company within their operations.
N/A = free text
• Keyword(s):
Water recycled, water recirculation, water recycling rate, water recirculation
rate
- Scoring:
o Place the percentage of the water that the company has
recycled/reused (water that was originally not a
recycled/reused water but was recycled/reused by the
company in their operation)
o The latest value (latest year) should be the same number
used in the Water recirculation/recycling rate datapoint
o Always indicate in the Internal Notes any data provided by the
company on the data point (e.g., why the data was placed or
why not the data was placed in Capture, calculations,
explanations on any data/disclosure, etc.)
o Refrain from calculating this data point as much as possible
unless it has been clear that the data is pertaining to the
water the company has reused in their operation
•If there is clear data on total water recycled and total

water withdrawal, calculate using: [(Total Water
Recycled/Total Water Withdrawal) * 100] to get the
percentage
o Do not confuse this with the water the company has
withdrawn/abstracted/taken from recycled/reused water
sources
the company or if data cannot be calculated
Details
• Definition: This data point refers to additional information/details on the
company’s water withdrawal data
N/A = free text
• Keyword(s):
intake, abstracted, water input, water withdrawn, freshwater, freshwater
withdrawal intensity, fresh water, surface water, tap water, municipal water,
groundwater (renewable and non-renewable), mine water (non-brackish),
potable water, utility, third-party, quarry water, entrained water, Fresh
surface water, including rainwater, water from wetlands, rivers, and lakes,
Groundwater – renewable, Groundwater – non-renewable, Third party
sources
- Scoring:
o This is where additional information provided by the
company on their water data will be placed (for Water
Withdrawal Performance table)
Performance – Water Consumption Performance

• IMPORTANT: Check the additional guidance for water
withdrawal/consumption.
• Different terms are used for water withdrawal and consumption including
"water use", "water usage", "water consumption", "water intake", "water
abstraction", "water withdrawal".
Year
• Definition: This data point refers to the year of all the available data placed
in the Water Consumption table
N/A = free text
• Keyword(s):
Water consumption, consumed water, water use, consumption, water
usage
- Scoring:
o Place the reporting year of the water data of the company
Scope of Reported Water Consumption Data

• Definition: This data point refers to the scope of the company’s water
consumption data is pertaining to.
(a) Covers all relevant operations or product segments
(b) Covers selected operations or product segments
• Keyword(s):
usage
on the company’s “Scope of the Report” or “About the Report” at the
- Scoring:
o Covers all relevant operations or product segments – water
consumption data is from all company operations/sites
o Covers selected operations or product segments – water
consumption data are on some of the company’s
operations/sites or if they have not mentioned the scope as
If the company uses pounds “all operations/sites” but
mentioned a specific company operation/site
o Scope not determinable – the scope of the water
consumption data is not identifiable/not provided by the
company or if the company does not have any water data
that can be placed on the water consumption table (no

disclosure)
Freshwater Consumption – Reported

• Definition: This data point refers to the value of company’s freshwater
usage/consumption. Water Consumption generally refers to the water that
the company has used/utilized in their operations.
N/A = free text
• Keyword(s):
Water consumption, water consumed, water use, consumption, water
usage, freshwater, fresh water, surface water, tap water, municipal water,
groundwater (renewable and non-renewable), mine water (non-brackish),
potable water, utility, third-party, quarry water, entrained water, Fresh
surface water, including rainwater, water from wetlands, rivers, and lakes,
Groundwater – renewable, Groundwater – non-renewable, Third party
sources
- Common terms include "consumed", "consumption", "use", “usage”
- Answer to this data point is also the answer to Fresh Water Used table
in Biodiversity and Land Use Key Issue
- Scoring:
o Place the total amount of the company’s freshwater
consumption. Always indicate in the Internal Notes any data
o If total freshwater consumption is not provided but the
breakdown of water consumption sources was disclosed,
add all the identified freshwater sources.
o If no freshwater consumption was identified in the water
withdrawal data or if the company did not explicitly provide
information on the freshwater consumption, leave this data
point blank but provide Internal Notes.
o NEVER calculate freshwater consumption by the formula:
Withdrawal – Discharge
- IMPORTANT NOTE:
o Assumption that can be used if no Freshwater Consumption
is provided/cannot be calculated but Freshwater
Withdrawal, Total Withdrawal, and Total Consumption are

provided/available
• If Freshwater Withdrawal = Total Withdrawal and
there is a value for Total Consumption, it is okay to
assume that Total Consumption is also the
Freshwater Consumption
• This assumption CANNOT go the other way around
(i.e., if Freshwater Consumption, Total
Consumption, and Total Withdrawal are provided
and Freshwater Consumption = Total consumption,
then Freshwater Withdrawal = Total Withdrawal)
Freshwater Consumption Intensity – Reported

• Definition: This data point refers to the value of the freshwater
consumption intensity of the company
N/A = free text
• Keyword(s):
Freshwater consumption intensity, freshwater, fresh water, surface water,
- This is only for the company’s freshwater consumption intensity. If it
is not clear that the data is pertaining to freshwater consumption
intensity, do not consider
- Scoring:
o Place the value of the freshwater consumption intensity
data of the company. Always indicate in the Internal Notes
any data provided by the company on the data point (e.g.,
why the data was placed or why not the data was placed in
Capture, explanations on any data/disclosure, etc.)
the company
Freshwater Consumption Intensity – Reported details (unit)

• Definition: This data point refers to the unit of the freshwater consumption
N/A = free text
• Keyword(s):
Freshwater consumption intensity, freshwater, fresh water, surface water,
- This is only for the company’s freshwater consumption intensity. If it
is not clear that the data is pertaining to freshwater consumption
intensity, do not consider
- Scoring:
o Place the unit of the freshwater consumption intensity of
the company or the freshwater consumption intensity data
description of the company
the company
Total Water Consumption – Reported

• Definition: This data point refers to the value of company’s total water
usage/consumption. Water Consumption generally refers to the water that
the company has used/utilized in their operations
N/A = free text
• Keyword(s):
usage
- Scoring:
o Place the total amount of the company’s total water
consumption. Always indicate in the Internal Notes any data
o If total consumption is not provided but the breakdown of
water consumption sources was disclosed, add all the
consumption data to get the total.
o If total consumption data was not provided by the company
or if the company did not explicitly provide that the
information is pertaining to total consumption, leave this
data point blank but provide Internal Notes (see Additional
Guidance)
o NEVER calculate total consumption by the formula:
Withdrawal – Discharge

• Definition: N/A
N/A = free text
• Keyword(s):
N/A
- Scoring:
Industry Metric Value Unit

• Definition: N/A
N/A = free text
• Keyword(s):
N/A
- Scoring:
Details
• Definition: This data point refers to additional information/details on the
company’s water consumption data
N/A = free text
• Keyword(s):
Water consumption, water consumed, water use, consumption, water

usage, freshwater consumption intensity, freshwater, fresh water, surface
water, tap water, municipal water, groundwater (renewable and non-
renewable), mine water (non-brackish), potable water, utility, third-party,
quarry water, entrained water, Fresh surface water, including rainwater,
water from wetlands, rivers, and lakes, Groundwater – renewable,
Groundwater – non-renewable, Third party sources
- Scoring:
o This is where additional information provided by the
company on their water data will be placed (for Water
Consumption Performance table)
Additional Guidance for Water Withdrawal / Water Consumption

Withdrawal vs Consumption
• Some of the companies discloses total freshwater
withdrawal/consumption that includes rainwater or other alternative water
sources (wherein, we do not classify this as freshwater). In that case, we
must manually calculate the freshwater withdrawal/consumption and
indicate in the "Details" field.
• Case 1: Disclosure of two data on water but does not have clear
distinctions of "withdrawal" and "consumption" (Example: company has
data on “water use” and “water consumption”)
- Use HIGHER Value as Withdrawal
- Use LOWER Value as Consumption
- Provide Internal Notes
• Case 2: One data on water (i.e., labelled as “water use”, “water
consumption”, “water usage”) and no data on water withdrawal (e.g.,
“water intake”, “water abstraction”, or “water withdrawal”),
- IVA Industries: Casinos & Gaming, Construction Materials, Containers
& Packaging, Hotels & Travel, Metals and Mining – Non-Precious
Metals, Metals and Mining – Precious Metals, Paper & Forest Products,
Steel Commented [ACJ133]: Pending query with Content
Team. Below query is available in Adhoc Teams
o Enter the data in Water Withdrawal Table and provide
Channel.
internal notes
- For IVA Industries not included above, analyze whether the data will fall Kindly confirm if Water Stress - Sector Specific table in
Adhoc Teams Channel should be followed on Water
under withdrawal or consumption. Ensure that Internal Notes are
Stress - Water Consumption / Withdrawal.
placed for explanation/analysis.
If there any other sectors need to be added, kindly
update the table.
o For example, fish producer company with a huge water

figure tagged as “water use/usage”. Based on disclosures,
the company uses freshwater to breed fish in the
hatcheries. While the disclosure is tagged as “water
use/usage”, the water is not really used as a raw material by
the company. The company discharges the water after use
so it will fall under withdrawal.
Categories of Freshwater and Alternative Sources
FRESHWATER SOURCES ALTERNATIVE SOURCES

Surface water (1) Others/Other(3)
Tap water Seawater
Municipal water Brackish water
Groundwater (regardless if renewable or Wastewater from another organization
non-renewable)
Mine water (non-brackish) Industrial water(4)
Potable water Non-potable water
Utility/Utility water Rainwater
Third-party sources (2) Produced water
Quarry Water Reclaimed water
Entrained water Recycled water
New water (1) Grey water/gray water
Processed water
Mine dewatering(5)
ADDITIONAL NOTES:
(1) If company stated that new water is NOT brackish, wastewater, processed, produced,
recycled/reused water OR has NOT undergone any processes of the company's operations yet, it is
FRESHWATER. If it is any of the things mentioned, it will be ALTERNATIVE
(2) Third party source could be alternative IF the water is wastewater FROM other third parties OR
reclaimed/recycled water from third parties.
(3) There could be cases where “Other” or “Others” source is FRESHWATER. This is ONLY IF the
company EXPLICITLY stated the same. Indicate INTERNAL NOTES for these cases
(4) Industrial water is considered as FRESHWATER for Japan issuers (only). For issues located in
other countries (excluding Japan), consider under ALTERNATIVE
(5) DO NOT CONFUSE WITH "MINE WATER". MINE WATER IS A FRESHWATER SOURCE
CDP FRESHWATER AND ALTERNATIVE SOURCES

[NOTE: Only follow below if source used is CDP Water W1.2h; below are the exact
names/categories found in the report]
FRESHWATER SOURCES ALTERNATIVE SOURCES
Fresh surface water, including rainwater, Brackish surface water/Seawater
water from wetlands, rivers, and lakes(6)
Groundwater – renewable Produced/Entrained Water(6)
Groundwater – non-renewable
Third party sources
ADDITIONAL NOTES:
(6) In CDP, the bifurcation of data is not that clear since they are still more or less aggregated.
Hence, we consider some sources based on the majority of the data being reported in the
standardized categories of CDP.
This is why, rainwater is considered as freshwater for CDP since majority of the other sources that
are aggregated with the rainwater are freshwater sources (fresh surface water, wetlands, rivers,
lakes).
Same goes with produced/entrained water. Most companies use produced water and only mining
companies have entrained water. Therefore, we follow the majority that the data submitted by
companies in CDP for Produced/Entrained water are mostly produced water which is alternative.
Rule for Freshwater Sources

• If there is a water source disclosed by the company but is not in the lists
above, the general rule in identifying freshwater is that any water that is
clean (not polluted with salt, pollutants, etc.) or can be drank is considered
as freshwater.
• If the source disclosed by the company is not on the list, we will consider
the source as freshwater unless otherwise stated that it is alternative,
brackish, reclaimed, recycled, etc.
Conversion Rule
• Do not convert gallons to m3, if company disclosed gallons, then input the data
as gallons. The only acceptable conversions to m3 are the ones below
o 1 megaliter = 1000 m3
o 1 ton water = 1m3
o 1000L = 1m3
• If company disclosed data in million m3, please refrain from using the "million
m3" in the units option in the water withdrawal and consumption and convert
data to m3
Rules of Sources
• AR vs CSR
- There are some cases where company consistently disclose water
data in AR/CSR but recently released in different report (AR/CSR) with
clearer bifurcation of sources. Hence, we must analyze:
o If values are far from each other, retain the older data then
use the clearer bifurcation of sources for latest year and
indicate in Internal Notes that AR/CSR was use due to
clearer bifurcation of water sources
o If the AR/CSR only have a small difference in units (i.e.,
thousands), then we could use the source with clearer
bifurcation but note in the Internal Notes of the changes
done.
• CDP vs AR/CSR:
- If previous year used CSR as source, then use CSR.
- If previous year used CDP as source, then use CDP.
- Exceptions:
o If previous year used CDP and current CDP is not yet
available, then use the available data from AR/CSR data and
indicate Internal Notes that CSR data is used for profiling.
Data will be replaced, once the CDP data is available.
o If CDP and CSR are both available, check the scope of the
data (i.e., Selected or All Operations). Choose the “All
operations” data and this should be higher than the selected
operations data. Indicate in Internal Notes the difference in
values.
• This case also applies when a company has newly
released their CDP report but data being used
historically are all from CSR [Exception: Food
Products and Beverages companies; see guidance
section on this industry below]
o Please also indicate in the Internal Notes the sources and
values of the “all operations” scope data for the older years
and change the historical values in the table.
o Check the company Fiscal year-end, if it’s aligned with CDP
(i.e., usually December year-end). Choose the data that
encompasses the whole fiscal year reporting of the
company (which is usually the CSR). Provide an internal
note as well.
- For Food Products and Beverages companies
o In case of discrepancies in water withdrawal and

consumption data disclosed in ESG report and CDP water,
we give greater weight to those disclosed in CDP Water.
Choose CDP Water data
- Utilities:
oNo specific ruling and it is on a case-to-case basis.
However, CSR sometimes have clearer data on
withdrawal/consumption data than CDP data.
o Be consistent with the last 3 years
- Chemicals:
o Use whichever has comprehensive data
o Be consistent with the last 3 years
Restated Data
• If the company has undergone a Corporate Action Event (e.g.,
divestment/acquisition/merger/restructuring) and has restated its
historical water consumption based on a CHANGE IN SCOPE, please do
NOT restate historical values.
• If the company reported correct value with the SAME SCOPE that’s the
ONLY time that we may change the historical values. Provide the original
values in the internal notes.
• If the latest report has been restated, use the restated values, then update
in the Internal Notes the original values.
Appendix I | QC Process
Back-to-Source
Back-to-Source is the manual quality check done by Data Ops. The check is done by
checking all the disclosures (i.e., Annual Report, CSR, ESG, etc.) to confirm the
updates made by the vendor.
Stop Publication Check

Stop Publication Check is a Capture enhancement that helps to immediately identify
errors based on guidelines, industry rules, and/or market rules. It prevents tasks with
unresolved validation rules error form being advanced. The parts of Stop Publication
Checks are as follows:
1. Stop Publication Check
1
2
3
1. Publication Check - Displays status if all items in Stop Publication Checks are
resolved.
2. Stop Publication Summary - Shows summary of unresolved errors in Stop
Publication Checks.
3. Stop Publication Override - Enables reviewer to override all errors in Stop
Publication Check even without providing comment on each error.
4. Stop Publication Checks - Provides all errors based on guidelines, industry
rules, and/or market rules.
2. Validation Log
Displays all data points and its status (i.e., Passed, Failed, Error, & Skipped). It is
helpful on tracking data points which needs to be resolved.
3. Quality Advisory
Displays all unresolved items of Validation Log. Note that there is no need to
comment on all errors in this table.
Ways to Fix ‘Fail’ Stop

Publication Check
1. Data point Fix – Resolve the error described in stop publication summary
No unresolved validation log error
2. Analyst Override Comment – Provide the reason of bypassing the validation

rule
Appendix II | Japan and China Default Scoring
Use the link for the consolidated Japan and China default scoring. Note that scoring
per data point are already reflected above.
Appendix III | Sources

Sources
10-K Human Rights Policy
Institutional Investors Group on Climate Change (IIGCC)
20-F / 40-F website
Advertising/ Communication/ Lending Practices Integrated Annual Report
Annual Information Form Investor Group on Climate Change (IGCC) website
Annual Report Investor Network on Climate Risk website
Articles of association Investor Presentation
Asia Investor Group on Climate Change (AIGCC) website Korean Sustainability Investing Forum (KoSIF)
Audit committee/ Risk committee charter Management Information Circular
Call Reports Management Report
CDP Meseting Notice
Norweigian Forum for Sustainable and Responsible Investment
Code of Conduct (NorSIF)
Company Website Pillar 3
Consumer Financial Protection Bureau (CFPB) Prospectus
Corporate Citizenship Report Reference Document / Reference Form
Credit Policy for Industries Registration Document / Universal Registration Document
CSR/Sustainability Report/ESG Report Responsible Investment Association Australasia (RIAA)
Customer Charter Responsible Investment Policy
D&I Policy SASB - standalone report
DANSIF SEC 17-A (Annual Reports)
Dart website Securities Report
Debt collection/ recovery policy SIF Ireland
DEF-14A spainSIF
EEI Reports Stewardship Policy
ESG Policy/Environmental Policy - standalone report Supplier's Code of Conduct
EU Taxonomy Reporting - standalone report Sustainability Data book
EuroSIF SWESIF
Factsheet Swiss Sustainable Finance (SSF)
FCA Database UKSIF
Financial Statements UN PRI report
FinSIF UN PRI website
Form S-1 UNSDG Report/ Website
Forum per la Finanza Sostenibile USSIF
Forum pour l'Investissement Responsable(FIR) Whistleblower Policy
Full Accounts Wolfesberg Questionnaire
Global Impact Report Yuka Shoken Hokokusho (YUHO)
Green Bond Framework
GRI
Grievance redressal mechanism
Appendix IV | Track Changes

Date Key Issue Data point Update Changes
Release made &
Approved by
06/15/2022 Corporate Provision of Whistleblower New procedure due to change in Riza Lo & Von
Behavior Protection dropdown options. Infante
06/20/2022 Common LM/HCD Salary per employee (in USD) Added information on salary per Riza Lo & Von
employee computation (i.e., Infante
company disclosure - average
monthly salary)
06/22/2022 Opportunities in All data points were reviewed by Cristine Atilano
Clean Technology the Content Team. & Von Infante
06/27/2022 Markets • Removed Argentina in EM – Riza Los
Americas and moved to MSCI
Standalone Market Indexes
• Removed Russia under EM –
Europe, Middle East & Africa and
moved to MSCI Standalone
Market Indexes
• Removed Pakistan under EM –
Asia and moved to FM - Asia
• Added Iceland and Slovenia
under FM – Europe
• Added various countries in MSCI
Standalone Market Indexes
Source: Market classification - MSCI
06/30/2022 All Key Issues Sources Added sources that will be used Riza Lo & Gino
in profiling. Cruz
*If there are any sources not in the
list, please raise it to us.
08/23/2022 Human Capital Employee Turnover For Supranationals, please Riza Lo & Jun
Development compare with 3-year average of Maruyama
banks.
08/23/2022 Disclosures Mortgage REITs Disclosures to be used. Riza Lo &
Kshitij Gupta
08/25/2022 Privacy and Data Rights provided to individuals Procedure on Right of deletion of Riza Lo, Kshitij
Security regarding the control of their individuals' data option. Gupta, &
data Reshmi Pillai
08/30/2022 Responsible - Policies and procedures to Mortgage REITs procedure. Riza Lo and
Investment integrate ESG considerations Kshitij Gupta
- Data points under Practices

– ESG factors incorporated
into investment processes
across the following asset
classes section.
- Data points under

Practices – Company
Engagement section.
08/31/2022 TEW - Non-hazardous Waste General guidance on Releases to Kim Delin and
Performance Land: Hazardous Waste and Non- Camille Castillo
- Hazardous Waste hazardous Waste Performance
Performance
08/31/2022 Access to Groups served including Clarification on default scoring Cristine Atilano
Communication developed markets data & Riza Lo
points
09/05/2022 Common LM/HCD Total number of employees Japan Domicile procedure Cristine Atilano
in executive management (C- & Riza Lo
suite)
Total number of employees
in senior management
(managers and above)
09/05/2022 Human Capital Number of women in Japan Domicile procedure Cristine Atilano
Development executive management & Riza Lo
Number of women in senior
management
09/09/2022 Privacy and Data Evidence of access control Financials procedure Riza Lo and
Security and protection of Kshitij Gupta
personal/sensitive data
Practices and consent

requirements around
handling of personal data by
third parties
9/12/2022 Common LM/HCD Percentage of total Additional scenarios for General Cristine Atilano
employees receiving training Procedure & Riza Lo
Annual training hours per
employee
9/12/2022 Human Capital Annual Employee Turnover Clarification on general guidance Cristine Atilano
Development Profit per Employee based on historical value & Riza Lo
09/15/2022 Common LM/HCD Please select frequency with Select “Surveys conducted Riza Lo & Von
which the company conducts sporadically” if child data point is Infantes
employee engagement scored as “Biennial or once every
surveys. two years” or surveys are done
once every three years or on the
ad-hoc basis only.
09/30/2022 Access to Finance All data points. Riza Lo &
Candy Ao
10/03/2022 Common LM/HCD Total number of employees China Domicile procedure Cristine Atilano
in executive management (C- & Riza Lo
suite)
Total number of employees
in senior management
(managers and above)
10/03/2022 Human Capital Number of women in China Domicile procedure Cristine Atilano
Development executive management & Riza Lo
Number of women in senior
management
10/04/2022 Biodiversity & Oil Spills Elaine Cariaso
Land Use & Anupam
Mujumdar
10/04/2022 Toxic Emissions & Non-hazardous Waste Scheduled vs Non-Scheduled Riza Lo and
Waste Performance Waste Camille Castillo
Hazardous Waste
Performance
10/10/2022 Common LM/HCD More than 10% of workforce New procedure for sources. Riza Lo, Gino
or more than 1,000 employee Cruz, Adrian
are affected by Mergers & Pacia, and Von
Acquisitions (M&A) Infante
10/10/2022 Common LM/HCD - Workforce eligible for No new procedure. Only Riza Lo, Gino
and Corporate material non-pay benefits additional information. Cruz, Adrian
Behavior - Employee stock ownership Pacia, and Von
plan (ESOP) or employee Infante
stock purchase plan (ESPP)
- Executive body responsible
for managing business ethics
and corruption issues
10/11/2022 Common LM/HCD Company discloses Select “Company discloses Riza Lo and
engagement survey results engagement results” if only child Von Infante
data points “Company discloses
engagement survey results” is
ticked.
10/14/2022 Opportunities in - Total Portfolio (number of New Guidance for Total Portfolio Cristine Atilano
Green Building buildings) and Green Building Certifications and Joyce
- Number of green certified Tansinco
buildings in portfolio
10/17/2022 Corporate - Audits of ethical standards No new procedure. Only Riza Lo, Gino
Behavior and anti-corruption practices additional information. Cruz, and
Definition and General Adrian Pacia
Procedure sections.
- Does the company conduct
audits of its ethical
standards?
- Does the company conduct
audit of its anti-corruption
policies?
- Does the company state
that it audits ALL operations?
10/17/2022 Corporate Company's bribery and anti- No new procedure. Only Riza Lo, Gino
Behavior corruption policy rephrased a line: Cruz, and
Generally, we can consider a Adrian Pacia
policy to be detailed and formal if
it includes expectations of
employees, monitoring, training
requirements and associated
corrective actions breaches in
expected behavior.
10/17/2022 Common LM/HCD - Engagement surveys to Additional guidance and samples. Riza Lo, Gino
monitor employee Cruz, and
satisfaction Adrian Pacia
- Managerial and leadership

development training
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Consolidated E&S Methodology - New - 25th Oct

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Opportunities in Nutrition Health 403

Data Collection Scope

Dual Listed Entities

Scoring Data Points

Content Analyst Updated the Data Point

ICP Updated the Data Point

QC Scope for Series Data Points

Non-Metric Data points under Non-Weighted Key Issue

4. AVOID doing the following:

3. AVOID doing the following:

d. Avoid any types of lines. e.g., ……. Or ======= OR -----------

Externally managed mREITs

o General statements to support essential services in

Groups served including developed markets

Inclusion of children in accessibility programs

- For any telecommunications with a business on tower infrastructure,

Inclusion of people with disabilities in accessibility programs

Inclusion of low-income households in accessibility programs

Inclusion of remote areas development in accessibility programs

- Important Note: if the company does not have a philanthropic activity

Current operations include

Ownership stakes in regional operators

Targets for Expansion

No expansion plans to EMs detected – No disclosure/ No

(d) Below-average level of SME finance

Emerging and Frontier Markets

• Guidelines for Specific Industry / Market

- Sub-Industry: Life & Health Insurance, Multi-line Insurance, Property

- Sub-Industry: Consumer Finance

SME lending growth rate (% year-on-year)

• Guidelines for Specific Industry / Market

- Default Scoring: leave data point as "No Value” (Not Applicable)

- Sub-Industry: Consumer Finance

SME business growth - assessment

oNo evidence of SME finance or significant year-on-year

• Guidelines for Specific Industry / Market

- Sub-Industry: Consumer Finance

Business to underserved communities (est. %)

- Examples: Microloans, hardship loans, and other lending targeting

Evidence of business to underserved communities (incl. rural

o Global leader in terms of business targeting underserved

• Guidelines for Specific Industry / Market

Extent of involvement in Microfinance/Microinsurance

(lending, debt, equity investment etc.), financing through

Innovation in Mobile / Online Distribution Channels

o Mobile/online distribution but no information on

• Guidelines for Specific Industry / Market

Reach of Points Service (Branches, ATMs, Self-Service, etc.)

• Guidelines for Specific Industry / Market

Innovation in Other Alternative Branchless Distribution Channels (e.g.

Bancassurance to reach those not otherwise served in this way,

Company Expansion/Access Strategy

Presence in emerging markets via direct operations or majority-owned

Extent of access to healthcare strategy in EMs/developing countries

Management system to implement and monitor its Access to

- Check if there is any oversight of a Board level committee over access

CSR or other committee oversees Access to Healthcare issues

Company’s disclosure of its Access to Healthcare-related

Explicit support of generic competition

Explicit support of entire Doha Declaration on TRIPS

General support of the Doha Declaration on TRIPS, with exceptions