Trucost Carbon Earnings
at Risk (CEaR)
Methodology
S&P Global Sustainable1

July 2024

Table of Contents
Terms and Definitions ............................................................................... 3
Introduction and Context .......................................................................... 4
Data Sources .............................................................................................. 5
Methodology Overview ............................................................................. 6
Developing the Carbon Price Risk Premium ..................................................................... 6
Applying the Carbon Price Risk Premium in Portfolio Carbon Risk Analysis .................... 8

Portfolio Aggregation ...............................................................................10
Portfolio’s Impact and ‘Exposure’: ................................................................................... 10
Portfolio’s Weighted Exposure: ....................................................................................... 10
Portfolio Carbon Earnings at Risk Indicators ................................................................... 10
Inputs ............................................................................................................................... 11

Monitoring and Review ............................................................................12
Assumptions and Limitations .................................................................12
Maintenance/Updates ...............................................................................12
Significant Updates ..................................................................................13
References ................................................................................................14
Appendix: Carbon Price Database ..........................................................15
S&P Global Sustainable1 Disclaimer ......................................................17

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2

Terms and Definitions
Carbon Price Risk Premium: The Carbon Price Risk Premium is the difference between the current price paid
per metric ton of greenhouse gas emissions and the possible future price for a particularsector/geography/scenario/year combination. It is a factor by which to multiply location-based company
The Carbon Price Risk Premium varies by geography due to government policy differences, and by sector due
to the differential treatment of sectors in many climate change policies. The sectors included are:
Agriculture and Fisheries, Electricity, Industry, International Aviation, Offroad Transport, Residential andCommercial Real Estate as well as Road Transport. Carbon Price Risk Premiums are available for 44 regions

EBIT: Earnings before interest and tax.
EBITDA: Earnings before interest, tax, depreciation and amortization.
EBIT(DA) Marginof its total revenue.
EV
debt, minority interest and preferred shares, minus total cash and cash equivalents.
Valuation Multiples: Metrics used for estimating a value and type (e.g. growth/value) on a relative basis of acompany. The analysis currently uses EV/EBIT and EV/EBITDA multiples.

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3

Introduction and Context
Research by leading institutions find that carbon prices in the most advanced economies will need to increase
to around $140 per ton by 2030 if the parties are to meet the goals of the Paris Agreement 1 . Measures toincrease the costs of carbon-emitting activities are transforming the underlying economics to favor lowercarbon technologies and products across all sectors, but especially in carbon-intensive industries.
In 2023, 52 national jurisdictions and 42 subnational jurisdictions, representing almost the totality of global
GHG emissions, implemented some sort of carbon pricing mechanism 2 . The number of companies
incorporating the potential impact of this in their risk management processes increased by 80% over a fiveyear period: in 2020, over 2,000 companies were pricing their emissions to manage carbon price risk 3.
In 2017, S&P Global Sustainable1 (S1) launched the Corporate Carbon Pricing Tool in order to help businesses
understand their potential exposure to future carbon price increases. The tool helps companies to set internalcarbon prices aligned to regional policy trends based on their sector and geographical exposure. This enables
them to stress test their financials and their capacity to withstand regulatory pressure and pass through costs,
benchmark their exposure to regulation against competitors, or prioritize low carbon innovation in locations
where the potential exposure is more material. S1 has developed a dataset of scenario-based future andcurrent carbon prices based on present emission trading schemes, carbon and fossil fuel taxes.
for the investment community to address two key best practice requirements outlined by the TCFD: conducting
scenario analysis and developing forward-looking estimates of financial risk. The analysis assesses thepotential impact to company earnings today, if companies had to pay a future price for their greenhouse gas
emissions.
This document outlines S1
earnings at risk. The methodology allows investors to measure the potential carbon price risk exposure
Carbon Earnings at Risk analysis enables market participants to:
•
•
•

•

Examine the potential financial impact of carbon prices at a constituent and portfolio level under arange of scenarios.
Report forward-looking estimates of financial risk.
Distinguish carbon price risk from broader carbon risk such as physical risks or possible stranded
assets.
Assess results against a chosen benchmark.

IEA.
(2023).
World
EnergyOutlook2023:
https://iea.blob.core.windows.net/assets/86ede39e-4436-42d7-ba2aedf61467e070/WorldEnergyOutlook2023.pdf
2
The World Bank. (2023). Carbon Price Dashboard: https://carbonpricingdashboard.worldbank.org/
3
CDP. (2021). Putting a price on Carbon: https://www.cdp.net/en/research/global-reports/putting-a-price-on-carbon/download.
1

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Data Sources
S1 has utilized the following public and proprietary financial and environmental data sources to derive its
analysis:-

The future carbon prices are determined by S1 based on the latest scenarios from the International
Energy Agency (IEA) 4.

-

Country and sector specific current carbon prices are determined by S1 based on data from World
Bank5, OECD, International Carbon Action Partnership (ICAP) 6 and other available sources.

-

Financial data comes from a variety of sources such as S1 and S&P Global Market Intelligence: For
EBIT, EBITDA and revenue, 3 year trailing averages are taken in order to smooth potential
irregularities in financial performance.

-

Trucost Environmental database.

Disclosure Project (CDP)7 or from revenues geographic breakdowns.

4 IEA. (2023). World Energy Outlook 2023: https://iea.blob.core.windows.net/assets/86ede39e-4436-42d7-ba2a-

edf61467e070/WorldEnergyOutlook2023.pdf
5
The World Bank. (2023). Carbon Pricing Dashboard: https://carbonpricingdashboard.worldbank.org/map_data
6

ICAP (2024). ETS Map: https://icapcarbonaction.com/en/ets-prices.

7

CDP. (2023). Carbon Disclosure Project. Retrieved from: https://www.cdp.net/en

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Methodology Overview
Developing the Carbon Price Risk Premium
In creating the framework for the Carbon Earnings at Risk analysis, S1 has used its dataset of future carbon
prices based on the latest scenarios from the International Energy Agency (IEA) and current carbon prices (e.g.
global emissions trading schemes, fossil fuel and carbon taxes). The IEA scenarios are widely referenced,
accepted and used by the market for scenario analysis purposes.
The approach deploys three possible scenarios:•

High Carbon Price Scenario:
Scenario and represents the implementation of policies that are considered sufficient to reducegreenhouse gas emissions in line with the goal of limiting climate change to 1.5°C by 2100 (the Paris
Agreement) with 50% probability.

•

Medium Carbon Price Scenario:(APS) and assumes that governments will meet in full- and on-time pledges to reduce greenhousegas emissions and limit climate change to 1.7 degrees Celsius by 2100 (with a 50% probability).

•

Low Carbon Price Scenario:
which looks at what countries are doing in practice and can be accordingly regarded as a business as
usual (BAU) scenario. This scenario is associated with a temperature rise of 2.4 degrees Celsius by2100 (with a 50% probability)

Error! Reference source not found. and Table 1 show the projected future carbon price for selected scenarios
and years.
Figure 1: Potential future carbon price trajectories in the High Carbon Price Scenario

Forcasted Prices per Tonne of CO2e
(USD 2023)

300
250

Advanced economies with net zero emissions
pledges

200

Emerging market and developing economies
with net zero emissions pledges

150

Selected emerging market and developing
economies (without net zero emissions
pledges)100

Other emerging market and developing
economies

50

Sub-Sahara and other countries without
policies / pledges

0
2030

2040

2050

Source: Sustainable1. Graph is provided for illustrative purposes.
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Table 1: Sample Future Carbon Prices by Country Group and Scenario
USD 2023 per tonne of CO2
High
Advanced economies with net zero emissions pledges
Emerging market and developing economies with NZE pledges
Selected emerging market and developing economies (without NZE pledges)
Other emerging market and developing economies
Sub-Sahara and other countries without NZE policies / pledges

2025
108
55
13
8
8

2030
140
90
25
15
15

2040
205
160
85
35
35

2050
250
200
180
55
55

USD 2023 per tonne of CO2
MediumAdvanced economies with net zero emissions pledges
Emerging market and developing economies with NZE pledges
Selected emerging market and developing economies (without NZE pledges)
Other emerging market and developing economies
Sub-Sahara and other countries without NZE policies / pledges

2025
104
25
0
0
0

2030
135
40
0
0
0

2040
175
110
17
17
0

2050
200
160
47
47
0

2025
75
18
0
0
0

2030
97
29
0
0
0

2040
115
72
7
7
0

2050
126
101
24
24
0

100
7
17
92
33

130
13
28
120
42

150
21
43
129
67

155
29
53
135
89

USD 2023 per tonne of CO2
Low
Advanced economies with net zero emissions pledges
Emerging market and developing economies with NZE pledges
Selected emerging market and developing economies (without NZE pledges)
Other emerging market and developing economies
Sub-Sahara and other countries without NZE policies / pledges
Country/Region specificCanadaChile, Colombia
China
European Union
Korea

NZE: Net Zero Emissions
Advanced economies with net zero emissions pledges: OECD countries except Mexico.
Emerging market and developing economies with net zero emissions pledges: China, India, Indonesia, Brazil and South Africa
Selected emerging market and developing economies (without net zero emissions pledges): North Africa, Middle East, Russia
and Southeast Asia (excluding Indonesia)

Source: IEA, 2023; Sustainable1 Analysis

When assessing potential risks under a certain scenario, the focus is not primarily in the future carbon price,as part of this carbon price is already embedded in current regulations and costs of a business. The risk isrooted in the additional costs, termed by S1 as the Carbon Price Risk Premium . This Carbon Price Risk
Premium, which varies by sector, geography, year and scenario, reflects the additional financial cost paid (permetric ton of emissions) from the price that is currently paid, due to potential future pricing or tax increases.

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Figure 2: The Carbon Price Risk Premium represents the cost increase from an existing price under a specific scenario

Source: Sustainable1. Chart is provided for illustrative purposes.

Rising carbon prices will have direct financial implications for businesses where regulations impose a higher
price on greenhouse gas emissions from the direct operations of the business. Companies also face indirect
financial risks associated with the pass-through of rising carbon prices, as suppliers seek to recover the
additional regulatory costs in part or in full through increased prices. S1 has reviewed published research on
the ability of the Utilities sector to pass through carbon costs in the form of higher electricity prices. This
review has been used to estimate the proportion of the increase in carbon prices on scope 2 emissions thatare passed from suppliers to companies and has been incorporated into the dataset.

Applying the Carbon Price Risk Premium in Portfolio Carbon Risk Analysis
what sector it operates in and in what jurisdictions it is emitting greenhouse gases. For sector mapping,standard 464 sectors have been mapped to the Organization for Economic Cooperation and Development
8(OECD)
:
1.
2.
3.
4.
5.
6.
7.

Agriculture and Fisheries
Commercial and Residential Real EstateElectricity
Industry
International Aviation
Offroad Transport
Road Transport

8 OECD/IEA. (2016). Effective Carbon Rates. Retrieved from Pricing CO2 through Taxes and Emissions Trading Systems.

Retrieved from: http://www.oecd.org/tax/effective-carbon-rates-9789264260115-en.htm
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8

A compan
primary S1emissions are taken from reported data to the Carbon Disclosure Project (CDP) 9 . Where companies do notreport to the CDP, S1
distribution. Together, the sector exposure and country-level emissions profiles allow for a granular-levelbottom-up calculation of carbon price risk exposure. Applying the relevant Carbon Price Risk Premiums to-level Unpriced Carbon Cost.
International Aviation Risk Premiums are calculated as an average of the Global Aviation risk premiums andcountry-specific Off-Road Transport risk premiums (which include domestic aviation).
Figure 3: The process of Carbon Earnings at Risk analysis

Source: S&P Global Sustainable1

9

CDP. (2023). Carbon Disclosure Project. Retrieved from: https://www.cdp.net/en
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requires S&Pprior written consent.

9Portfolio Aggregationlevel. Below are two different methodologies that are used in the analysis.

S1
an approach, is built on the principle of ownership. That is, if an investor owns or in the case of debt holdings,
finances
portfolio level resources and associated risks are the sum of all these quantities.

For the remainder of the portfolio metrics, we use a Weighted Average approach. This approach assesses theportfolio). The weighted average aggregatio
risk exposures to the surface and shed light on whether the portfolio has too much of its value invested inthese companies.

Portfolio Carbon Earnings at Risk Indicators
The table below describes each of the financial metrics included in the Carbon Earnings at Risk analysis,
available for all major world currencies. All metrics are available using a weighted-average methodology, withthe exception of the Unpriced Carbon Cost, which is presented on an apportioned basis. Besides the below
benchmark.
Table 2: List of major metrics and considerations

MetricUnpriced
Cost

CarbonApportioned
Unpriced Carbon
Cost

Description

Use Case

The total additional costs arising(in)directly in a scenario/year for aparticular company

At the company and site level, locationbased Unpriced Carbon Cost can serve as
inputs for deeper analysis of financial risk
implications

The
Unpriced
CarbonCost
multiplied by the percentage
ownership an investor holds in acompany

The apportioned Unpriced Carbon Cost
offers investors a view as to the relativerisk exposure of each of their holdings aswell as an approach for reporting forwardlooking estimates of financial risk thataligns with TCFD guidelines

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EBIT(DA) at risk

The percentage of Earnings at Risk
due to Unpriced Carbon Cost

Highlights areas of risk across theportfolio and can be fed into financial
analysis

Reduction of
EBIT(DA) margins

Implied change in EBIT(DA) margins
based on a scenario/year comparedto the current margins

The metric allows for signaling of red flagsin the portfolio where the deterioration of
margin is significant

Value of Holdings
above a risk
thresholdTotal Value of Holdings where
EBIT(DA) at risk is above a certain
threshold (e.g. 10%)

Identifies companies that are facing themost significant carbon price risk acrossthe portfolio

Change in multiples

Implied change in a valuation
multiple due to reduced earnings ina scenario/year

Assessment of the overall implications on
the valuations of companies

Top geographical,
sector and emission
scope exposure

Exposure to countries, sectors or
scopes of emissions due to theapportioned Unpriced Carbon Cost

Assessment of hotspot areas within aportfolio

EBIT and EBITDA are preferred choices when it comes to selecting financials as proxies to measure risk
exposure. On the one hand, carbon prices affect costs hence there is no direct link to revenues, but rather
earnings. Yet not all earning indicators are suitable for use in this analysis. For example, net income isinfluenced by extraordinary items and financial costs. On the other hand, EBIT and EBITDA are indicators ofcore earnings capacity widely used by analysts for financial assessments and valuations. The preference
between EBIT and EBITDA normally depends on the specific sectors, however one or the other should be usedconsistently in the analysis when calculating the metrics for a portfolio.
There are additional considerations to take into account with regards to the financials of the companies.
Earnings can be volatile due to non-recurring costs or revenues, and increases in raw material costs that are
not categorized in extraordinary items in the income statement. To smooth these possible volatilities, S1 uses
the latest 3 year trailing averages of Revenue, EBIT and EBITDA when calculating earnings at risk metrics.
Sustainable1 does not take forecasted EBIT(DA) data into account when quantifying Earnings at Risk.

InputsFor Sustainable1 to calculate the Carbon Earnings at Risk portfolio footprint, just two inputs are required:••Company identifiers (e.g. ISIN)
Value of holdings or weights and the total value of holdings

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Monitoring and Review
All new methodologies and any material changes to existing methodologies are reviewed and approved by an independent
methodology governance committee.

Assumptions and Limitations-

Future carbon prices are estimated based on hypothetical future scenarios and may not reflect theactual carbon price in future years. As such, the scenarios are not projections for the future and areused without a probability estimate for the actual policy pathways to materialize. Probability factors
can be applied to the Unpriced Carbon Cost by clients based on their own views.

-

Companies are classified according to their primary sector.

-

Where no geographical breakdown of emissions is available, a proxy of geographical revenue is used.
This proxy is not necessarily fully aligned with the locations of emissions production.

-

Present-day financials and emissions are used throughout the analysis, without assumptions on
future trajectories. Clients however can use constituent level Unpriced Carbon Cost data to integrate
in their financial projections.

Maintenance/Updates
We periodically review our methodology as appropriate.

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12Significant Updates-

July 2024: S1 adopted a new source of future carbon price projections transitioning to the IEA 2023
future carbon price scenarios110 and retiring the previously used scenarios based on IEA and IRENA(2017)11 and Climate Action Tracker12. The updated future carbon price scenarios published by the IEA
in 2023 reflect the most recent advances in global climate policy and changes in the economy andenergy system.

-

July 2024: S1 expanded the geographic coverage included in the carbon price database to reflect:o Updated country specific current carbon price data sourced from the OECD and other sources 13
o Updated country groupings for which the IEA projects future carbon prices in each of the three
scenarios14.

10

EA. (2023). World Energy Outlook 2023. https://iea.blob.core.windows.net/assets/86ede39e-4436-42d7-ba2aedf61467e070/WorldEnergyOutlook2023.pdf
11OECD/IEA. (2017). Perspectives for the energy transition. https://www.irena.org//media/Files/IRENA/Agency/Publication/2017/Mar/Perspectives_for_the_Energy_Transition_2017.pdf .
12
The Climate Action Tracker Consortium. Climate Action Tracker. https://www.climateactiontracker.org/ .
13
OECD. (2023). https://stats.oecd.org/?datasetcode=ecr
14
IEA. (2023). World Energy Outlook 2023. https://iea.blob.core.windows.net/assets/86ede39e-4436-42d7-ba2aedf61467e070/WorldEnergyOutlook2023.pdf
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References
Carbon Pricing Leadership Coalition. (2024). Carbon Pricing in Action. Retrieved fromhttps://www.carbonpricingleadership.org/who/
CDP. (2023). Carbon Disclosure Project. Retrieved from: https://www.cdp.net/en
CDP. (2016). Embedding a carbon price into business strategy. Retrieved from CDP:
https://6fefcbb86e61af1b2fc4c70d8ead6ced550b4d987d7c03fcdd1d.ssl.cf3.rackcdn.com/cms/reports/documents/000/001/132/original/
CDP_Carbon_Price_report_2016.pdf?1474899276
CDP. (2021). Putting a price on Carbon: https://www.cdp.net/en/research/global-reports/putting-a-priceon-carbon/download.
European Union. (2018). COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE
EUROPEAN COUNCIL, THE COUNCIL, THE EUROPEAN CENTRAL BANK, THE EUROPEAN ECONOMIC AND
SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS Action Plan: Financing Sustainable Growth.
Retrieved from EUR-Lex: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52018DC0097
ICAP (2024). ETS Map: https://icapcarbonaction.com/en/ets-prices
IEA. (2023). World Energy Outlook 2023: https://iea.blob.core.windows.net/assets/86ede39e-4436-42d7ba2a-edf61467e070/WorldEnergyOutlook2023.pdf
OECD/IEA. (2017). Chapter 2 of Perspectives for the energy transition investment needs for a low-carbon
energy system. Retrieved fromhttp://www.irena.org/DocumentDownloads/Publications/Perspectives_for_the_Energy_Transition_2017.pdf
OECD/IEA. (2016). Effective Carbon Rates. Retrieved from Pricing CO2 through Taxes and Emissions Trading
Systems. Retrieved from: http://www.oecd.org/tax/effective-carbon-rates-9789264260115-en.htm
PRI. (2014). The Montreal Carbon Pledge. Retrieved from http://montrealpledge.org/
UNFCCC. (2018). What is the Paris Agreement? Retrieved from United Nations Climate Change:
https://unfccc.int/process-and-meetings/the-paris-agreement/what-is-the-paris-agreement
Timmer, M. P., Dietzenbacher, E., Los, B., Stehrer, R. and de Vries, G. J. (2015), An Illustrated User Guide to
the World Input Output Database: the Case of Global Automotive Production, Review of International
Economics., 23: 575 605
The World Bank. (2023). Carbon Pricing Dashboard: https://carbonpricingdashboard.worldbank.org
WIOD. (2017). World Input-Output Database. Retrieved from: http://www.wiod.org/home

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Appendix: Carbon Price Database
The geographic coverage included in the carbon price database is summarized in Table 3 below.
Table 3: Sustainable1 Carbon Price Database: Geographic CoverageCountries

Country Grouping

Argentina

Other emerging market and developing economies

Australia

Advanced economies with net zero emissions pledges

Austria

Advanced economies with net zero emissions pledges

Bangladesh

Sub-Sahara and other countries without policies / pledges

Belgium

Advanced economies with net zero emissions pledges

BrazilEmerging market and developing economies with net zero emissions pledges

Burkina Faso

Sub-Sahara and other countries without policies / pledges

CanadaAdvanced economies with net zero emissions pledges

Chile

Advanced economies with net zero emissions pledges

China

Emerging market and developing economies with net zero emissions pledges

Colombia

Advanced economies with net zero emissions pledges

Costa Rica

Advanced economies with net zero emissions pledges

Cote d'Ivoire

Other emerging market and developing economies

CyprusAdvanced economies with net zero emissions pledges

Czech Republic

Advanced economies with net zero emissions pledges

Denmark

Advanced economies with net zero emissions pledges

Dominican Republic

Sub-Sahara and other countries without policies / pledges

EcuadorOther emerging market and developing economies

Egypt

Selected emerging market and developing economies (without net zero pledges)

Estonia

Advanced economies with net zero emissions pledges

Ethiopia

Other emerging market and developing economies

Finland

Advanced economies with net zero emissions pledges

FranceAdvanced economies with net zero emissions pledges

Germany

Advanced economies with net zero emissions pledges

Ghana

Other emerging market and developing economies

GreeceAdvanced economies with net zero emissions pledges

GuatemalaOther emerging market and developing economies

Hong Kong

Emerging market and developing economies with net zero emissions pledges

Hungary

Advanced economies with net zero emissions pledges

Iceland

Advanced economies with net zero emissions pledges

India

Emerging market and developing economies with net zero emissions pledges

Indonesia

Emerging market and developing economies with net zero emissions pledges

Ireland

Advanced economies with net zero emissions pledges

IsraelAdvanced economies with net zero emissions pledges

Italy

Advanced economies with net zero emissions pledges

Jamaica

Sub-Sahara and other countries without policies / pledges

Japan

Advanced economies with net zero emissions pledges

Kenya

Other emerging market and developing economies

Korea, Rep.

Advanced economies with net zero emissions pledges

Kyrgyzstan

Sub-Sahara (Excluding South Africa) and Other Asian countries without pledges

LatviaAdvanced economies with net zero emissions pledges

Lithuania

Advanced economies with net zero emissions pledges

Luxembourg

Advanced economies with net zero emissions pledges

Macau

Emerging market and developing economies with net zero emissions pledges

Madagascar

Sub-Sahara and other countries without policies / pledges

Malaysia

Selected emerging market and developing economies (without net zero pledges)

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MexicoSelected emerging market and developing economies (without net zero emissions pledges)

MoroccoSelected emerging market and developing economies (without net zero pledges)

Netherlands

Advanced economies with net zero emissions pledges

New Zealand

Advanced economies with net zero emissions pledges

Nigeria

Other emerging market and developing economies

NorwayAdvanced economies with net zero emissions pledges

PanamaOther emerging market and developing economies

Paraguay

Other emerging market and developing economies

Peru

Other emerging market and developing economies

Philippines

Selected emerging market and developing economies (without net zero pledges)

PolandAdvanced economies with net zero emissions pledges

Portugal

Advanced economies with net zero emissions pledges

Russian Federation

Selected emerging market and developing economies (without net zero pledges)

RwandaSub-Sahara and other countries without policies / pledges

Singapore

Advanced economies with net zero emissions pledges

Slovak Republic

Advanced economies with net zero emissions pledges

Slovenia

Advanced economies with net zero emissions pledges

South Africa

Emerging market and developing economies with net zero emissions pledges

Spain

Advanced economies with net zero emissions pledges

Sri Lanka

Other emerging market and developing economies

SwedenAdvanced economies with net zero emissions pledges

Switzerland

Advanced economies with net zero emissions pledges

TurkeyAdvanced economies with net zero emissions pledges

UgandaSub-Sahara and other countries without policies / pledges

UkraineOther emerging market and developing economies

United Kingdom

Advanced economies with net zero emissions pledges

United States

Advanced economies with net zero emissions pledges

Uruguay

Other emerging market and developing economies

Source: S&P Sustainable 1 Analysis

For those countries not included in the database, the CEAR dataset will continue to use a category called Other,

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conflicts of interest for Sustainable1 as an organization and for individual employees. Such measures include, without
limitation, establishing a clear separation between the activities and interactions of its analytical teams and nonanalytical teams; email surveillance by compliance teams; and policy role designations. In addition, S&P Global employees
are subject to mandatory annual training and attestations and must adhere to the Sustainable1 Independence andObjectivity Policy, the Sustainable1 Code of Conduct, the S&P Global Code of Business Ethics and any other related
policies.
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