SECOND PARTY OPINIONSUMITOMO MITSUI BANKING CORPORATION
TRANSITION FINANCE PLAYBOOK PERIODICREVIEW (1ST)
Prepared by: DNV Business Assurance Japan K.K.
Location: Kobe, Japan
Date: 11 April 2024
Ref. Nr.: PRJN- 513786-2023-AST-JPN-02

Table of Contents
I. Scope and Objectives

3

Ⅱ. Project Overview

5

Ⅲ. Responsibilities of SMBC and DNV

5

Ⅳ. Basis of DNV’s Opinion

5

V. Work Undertaken

7

Ⅵ. Findings and DNV’s Opinion

8

Schedule-1 Eligibility Assessment Protocol for Transition Finance in the Format of Use of Proceeds
Instruments as the Enabler

13

Revision History
Revision
Number0

Date of Issue
11 April 2024

Remarks
First edition

Disclaimer
Our assessment relies on the premise that the data and information provided by Issuer to us as part of our review procedures have been provided in good faith.
Because of the selected nature (sampling) and other inherent limitation of both procedures and systems of internal control, there remains the unavoidable riskthat errors or irregularities, possibly significant, may not have been detected. Limited depth of evidence gathering including inquiry and analytical procedures andlimited sampling at lower levels in the organization were applied as per scope of work. DNV expressly disclaims any liability or co-responsibility for any decision aperson or an entity may make based on this Statement.

Statement of Competence and Independence
DNV applies its own management standards and compliance policies for quality control, in accordance with ISO/IEC 17021:2011 - Conformity Assessment
Requirements for bodies providing audit and certification of management systems, and accordingly maintains a comprehensive system of quality control, including
documented policies and procedures regarding compliance with ethical requirements, professional standards and applicable legal and regulatory requirements. We
have complied with the DNV Code of Conduct1 during the assessment and maintain independence where required by relevant ethical requirements. This
engagement work was carried out by an independent team of sustainability assurance professionals. DNV was not involved in the preparation of statements ordata included in the Framework except for this Statement. DNV maintains complete impartiality toward stakeholders interviewed during the assessment process.

1 DNV Code of Conduct is available from DNV website (www.DNV.com)

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I. Scope and Objectives
Sumitomo Mitsui Banking Corporation (hereinafter, “SMBC”) has commissioned DNV Business
Assurance Japan K.K. (hereinafter, “DNV”) to conduct a transition finance postimplementation periodic review as an Enabler based on the Transition Finance Playbook(hereinafter, the “Playbook”). The objective of the periodic review of DNV is to conduct anassessment to confirm that SMBC, as an Enabler, meets the criteria such as GLP, GLGLs, andother relevant standards or guidelines (see the table below) required for the implementationand management of individual finance based on the eligibility assessment process (decisionmaking process) with reference to the CTFH, CTFBG, and CTFWP or ATFG to be carried out
against the borrower, and to provide a second party opinion on the eligibility of the transition
finance based on this Playbook.
SMBC established the Playbook in April 2023. DNV has conducted a periodic review (1st)following the Transition Finance Playbook Second Party Opinion (issued 15 May 2023).
DNV, as an independent external reviewer, has identified no real or perceived conflict ofinterest associated with the delivery of this second party opinion for SMBC.
In this paper, no assurance is provided regarding the financial performance of the transition
finance, the value of any investment or loan, or the long-term environmental benefits of thetransaction.

(1) Standards/guidelines to be applied
Applicationlevel*4*5

No.

Standards/Guidelines

Scheme owner

1.

Climate Transition FinanceHandbook (CTFH)*1

International Capital Market Association(ICMA), 2020

Refer

Basic Guidelines on Climate
Transition Finance (CTFBG)*1

Financial Services Agency, Ministry of
Economy, Trade and Industry, Ministry of
the Environment, 2021

Refer

2.

3.

NZBA Transition Finance Guide(NZBA-TFG)

United Nations Environment Programme Finance Initiative (UNEP-FI), 2022

Refer

4.

Financing Credible Transitions(White Paper) (CTFWP)*2

Climate Bonds Initiative, 2020

Refer

5.

Green Loan Principles (GLP)*3

Loan Market Association (LMA) et al, 2021

Apply

6.

Green Loan Guidelines (GLGLs)*3

Ministry of the Environment, 2022

Apply

7.
*1

Asia Transition FinanceRefer
ATF Study Group, 2022
Guidelines (ATFG)
Climate transition: The concept of climate transition focuses principally on the credibility of an issuer’s
climate change-related commitments and practices (quoted from CTFH and CTFBG).

*2

An internationally and widely recognized white paper that comprehensively describes several industryspecific examples and the concept of transition finance at the organizational and project level.

*3

It confirms compliance with the four core elements (use of proceeds, process for project evaluation andselection, management of proceeds, and reporting) that must be met when implementing as aPage 3 of 19

bond/loan that meets the four elements of transition and has a specific use of proceeds (quoted andedited from CTFBG).
*4

Refer: Assessment of whether SMBC has an adequate eligibility assessment process for some of theapplicable requirements of each principle and guideline element necessary when assessing theborrower’s transition finance initiatives as an Enabler.

*5

Apply: Assessment of whether SMBC is eligible or has an eligibility assessment process to determine
eligibility for all elements of each principle and guideline necessary when implementing transition
finance as an Enabler.

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Ⅱ. Project Overview
Between May 2023 and February 2024, SMBC evaluated and selected 18 transition financeprojects based on the Playbook.
The eligible projects are in the gas and power sectors and are not restricted to specificregions. They are classified in the Playbook as Project Finance (PF), General Corporate
Finance (GCP)*1, and Use of Proceeds Finance (UoP). DNV sampled 18 representative
projects and conducted an assessment of whether SMBC, as an Enabler, properly
evaluated and selected them based on the Playbook.
*1: SMBC considers the execution of a transition strategy based on the borrower’s business activities as a“project.”

Ⅲ. Responsibilities of SMBC and DNVSMBC has provided the information and data used by DNV during the delivery of thisreview. Our Second Party Opinion represents an independent opinion and is intended to
inform SMBC and other interested stakeholders as to whether the established criteria havebeen met, based on the information provided to us. In our work, we have relied on theinformation and the facts presented to us by SMBC.
DNV is not responsible for any aspect of the assets referred to in this opinion and cannot
be held liable if estimates, findings, opinions, or conclusions are incorrect. Thus, DNV shallnot be held liable if any of the information or data provided by SMBC’s management andused as a basis for this assessment were not correct or complete.

Ⅳ. Basis of DNV’s Opinion
To provide as much flexibility as possible for SMBC, DNV has adapted our transition financeassessment methodology, which incorporates the requirements of CTFH, CTFBG, GLP, andGLGLs as well as the concepts presented in CTFWP and ATFG to create SMBC specific
Transition Finance Eligibility Assessment Protocol (hereinafter, “DNV’s Protocol”) as an
Enabler. Please refer to Schedule-1 for details. The Protocol is applicable to transition
finance transactions implemented by SMBC as an Enabler under CTFH, CTFBG, GLP, andGLGLs and with reference to CTFWP and ATFG.
DNV, as an independent external reviewer, provides second party opinion according to theProtocol.
DNV’s Protocol includes a set of suitable criteria that can be used to underpin DNV’sopinion. The overarching principle of the Climate Transition Finance behind the criteria is asfollows:

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“provide investment opportunities necessary for climate transition finance to be executedwith transparency and credibility”

As per our Protocol, the criteria against which the transition finance has been reviewed aregrouped under the below Principles, respectively, as indicated by CTFH, CTFBG, GLP, andGLGLs.
Note that (1) below will be reviewed as part of (2), as it is assessed by the Enabler in
Principle 2 of (2).

(1)

Transition finance eligibility assessment of the borrower as an Enabler(Four common elements of CTFH and CTFBG)

DNV will conduct a review of the execution status of the appropriate eligibility
assessment process for the following elements when SMBC, as an Enabler, assesses
the borrower’s transition finance initiatives.
Principle One:

Issuer’s climate transition strategy and governance

The fundraising purpose should be shown to enable the realization of the borrower’s
climate change strategy.
Principle Two:Business model environmental materiality

The planned climate transition pathway should be relevant to the environmental
materiality of the borrower’s business model.
Principle Three:

Climate transition strategy to be ‘science-based’ including
targets and pathways

The borrower’s climate transition strategy should reference scientific evidence.
Principle Four:

Implementation transparency

Market communication in connection with the offer of a financing instrument which has
the aim of funding the borrower’s climate transition strategy should also provide
transparency of the underlying investment program.

(2)

Eligibility assessment as use of proceeds transition finance(Four common elements of GLP and GLGLs)

Principle One:Use of Proceeds

The Use of Proceeds criteria are guided by the requirement that the proceeds fromtransition finance must be used for eligible projects through an Enabler and/or aborrower of a use of proceeds transition finance. The eligible projects should produce
clear environmental benefits.
Principle Two:

Process for Project Evaluation and Selection

The Process for Project Evaluation and Selection criteria are guided by the requirementthat an Enabler and/or a borrower of a transition finance should outline the process it
follows when determining eligibility of an investment using transition finance proceeds,
and outline how the project considers impact on the objective.

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Principle Three:

Management of Proceeds

The Management of Proceeds criteria are guided by the requirements that a transition
finance should be tracked by the Enabler and/or the borrower, that separate portfolios
should be created when necessary, and that a declaration of how unallocated proceeds
will be handled should be made.
Principle Four:

Reporting

The Reporting criteria are guided by the recommendation that at least Sustainability
Reporting should be issued by the borrower to the Enabler on the allocation status ofproceeds and that quantitative and/or qualitative performance indicators should be
used, where feasible.

V. Work Undertaken
Our work constituted a high-level review of the available information, based on theunderstanding that this information was provided to us by the Enabler in good faith. We
have not performed an audit or other tests to check the veracity of the information provided
to us. The work undertaken to form our opinion included:i. Transition finance pre-implementation assessment•

Creation of the Enabler-specific Protocol, adapted to the purpose of the Enabler’s
Transition Finance, as described above and in Schedule-1 to this assessment;•

Assessment of documents provided by the Enabler related to transition financetransactions and supplemental assessment by a comprehensive desktop research.
These checks refer to current assessment best practice and standard methodologies;•

Discussions with the Enabler and review of relevant documentation;•

Documentation of findings against each element of the criteria;•

Where necessary, documentation of an eligibility assessment against the assessment
results of the borrower’s transition finance executed by the Enabler.

ii. Transition finance post-implementation assessment (content of thisreport)•Interviews with the Enabler and review of the relevant documentation;•

On-site visits and inspections (if necessary);•

Documentation of post-implementation assessment results.

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Ⅵ. Findings and DNV’s Opinion
DNV's findings and opinions are as described below.
DNV reviewed the execution status of the eligibility assessment process for which SMBC, as
an Enabler, was assessed as eligible for the following elements when assessing theborrower’s transition finance initiatives.
(1) Findings and DNV’s opinion against four elements required for the
management of use of proceeds transition finance (TF) (see GLP and GLGLs)
TF-1. Use of Proceeds:
DNV has confirmed that 18 projects were selected and labeled as transition financebetween May 2023 and February 2024 based on the Playbook established by SMBC.
DNV has also confirmed that the funds provided fall under PF, GCP, or UoP for the gas
and power sectors.

TF-2. Process for Project Evaluation and Selection:
DNV has confirmed through the review that the projects for which the proceeds toexecute the borrowers’ transitions were selected by SMBC in accordance with the
Playbook and with the involvement of the Sustainability Department and relevant
departments.
In addition, DNV has confirmed that SMBC followed a predetermined process and criteria
for the assessment and selection of such projects, including implementation of reviews ofasset criteria, transition strategy criteria, compliance with the “SMBC Group
Environmental and Social Framework,” credit assessment, reputational risk, financed
emissions etc.
However, as some of the sampled projects contained yet to be determined elements,
specifically in the borrowers’ transition strategy and target setting compared to therequirements of the Playbook and related documents, DNV judges that a continuous
evaluation and monitoring is necessary to ensure the eligibility to transition finance of theabove-mentioned projects.
The following (Reference) outlines the process for evaluation and selectionpredetermined in the Playbook.

(Reference)
Process 1: Asset criteria *PF and UoPLabel asset eligibility based on Internal Taxonomy“Green,” “Yellow,” “Red,” etc.
Process 2: Transition strategy criteria *All types of finance including the above and GCP (general
corporate purpose)

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Assess Enabler CTF-1 to CTF-4 for the borrowers’ eligibility for transition
finance based on a checklist (in addition, “other criteria” are set for eachof the three target categories, which take exceptions into considerationand conduct more detailed process assessment).
Process 3: Confirm the compliance with the “SMBC Group Environmental and Social
Framework” *All types of finance↓Complete transition finance eligibility assessment *All types of finance(As necessary, the labelling of Process 1 may be changed or “Other” may be
used if it is not included in any of these.)↓
Process 4: Implement the credit assessment and reviews regarding reputational risk,
financed emissions, etc. *All types of financeTF-3. Management of Proceeds:
DNV has conducted a review of how SMBC confirms on borrowers’ cash management.
Transition finance under the Playbook is currently at the start of implementation and the
management results of the proceeds on an annual basis, as defined in the Playbook, areexpected to be confirmed in detail during the next periodic review.
SMBC has confirmed through reports from the borrower (either through written
submissions or interviews) prior to the loan that there are procedures in place to ensurethat the proceeds raised by the borrower through transition finance are managed inaccordance with the borrower’s internal processes.
SMBC has confirmed that the total amount of eligible transition projects will be managed
using the borrower’s systems and forms to ensure that it is not less than the transition
finance proceeds and will be reported to SMBC on an annual basis. SMBC has also
confirmed that it will ensure that the proceeds raised by the borrower are managed in
cash or cash equivalents until the proceeds are allocated.
DNV has confirmed that both are planned to be monitored by SMBC at least once a year
until all loan amounts have been allocated.

TF-4. Reporting:Transition finance under the Playbook is currently at the start of implementation and theannual reporting, as defined in the Playbook, is expected to be confirmed in detail fromthe next periodic review.
In such reporting, DNV has confirmed that the borrower will be required to report to
SMBC on the allocation status of proceeds and environmental benefits, and that SMBC will
be required to monitor changes in, and implementation of, the transition strategy of themain sponsor and the borrower at least once a year during the loan period.

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DNV has also confirmed that SMBC plans to report annually on the status of its
sustainable finance and other initiatives, including transition finance, in a Sustainability
Reporting such as TCFD report.

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Assessment Conclusion
On the basis of the Playbook and other relevant documentation and information provided
by SMBC, DNV has confirmed that SMBC is proceeding with the evaluation and selectionof projects and the implementation of finance in accordance with the requirements of the
Playbook established to implement transition finance as an Enabler. However, as some ofthe sampled projects contained yet to be determined elements, specifically in the
borrowers’ transition strategy and target setting compared to the requirements of the
Playbook and related documents, DNV judges that a continuous evaluation andmonitoring is necessary to ensure the eligibility to transition finance of the abovementioned projects.

Based on the above, it is DNV’s opinion that the transition finance transactions
implemented by SMBC as an Enabler is aligned with the definition and purpose oftransition finance that is to “provide investment opportunities necessary for climatetransition finance to be executed with transparency and credibility,” even though there
are some cases where ongoing monitoring and evaluation are deemed necessary.

DNV Business Assurance Japan K.K.
11 April 2024

Naoki Maeda

Jun Chokai

Managing Director/SCPA Vice President

Technical Reviewer

DNV Business Assurance Japan K.K.

DNV Business Assurance Japan K.K.

Masato Kanedome

Hisashi Hashimoto

Project Leader

Assessment Leader

DNV Business Assurance Japan K.K.

DNV Business Assurance Japan K.K.

About DNV
Driven by our purpose of safeguarding life, property and the environment, DNV enables organisations to advance thesafety and sustainability of their business. Combining leading technical and operational expertise, risk methodology andin-depth industry knowledge, we empower our customers’ decisions and actions with trust and confidence. We
continuously invest in research and collaborative innovation to provide customers and society with operational andtechnological foresight.

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With our origins stretching back to 1864, our reach today is global. Operating in more than 100 countries, our 16,000
professionals are dedicated to helping customers make the world safer, smarter and greener.

Disclaimer
Responsibilities of the Management of the Issuer and the Second-Party Opinion Providers, DNV : The management ofIssuer has provided the information and data used by DNV during the delivery of this review. Our statement represents
an independent opinion and is intended to inform the Issuer management and other interested stakeholders in the Bond
as to whether the established criteria have been met, based on the information provided to us. In our work we haverelied on the information and the facts presented to us by the Issuer. DNV is not responsible for any aspect of thenominated assets referred to in this opinion and cannot be held liable if estimates, findings, opinions, or conclusions areincorrect. Thus, DNV shall not be held liable if any of the information or data provided by the Issuer’s management andused as a basis for this assessment were not correct or complete

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Schedule-1 Eligibility Assessment Protocol for Transition Finance in the Format of Use ofProceeds Instruments as the Enabler-

The following checklists (GLP-1 through GLP-4) are the DNV assessment protocol created for the eligibility assessment of the Playbook of SMBC as the Enabler
based on the requirements of the GLP and GLGLs. The “Confirmed documents” in the “Work Undertaken” column include the Enabler’s internal documents andare provided by SMBC to DNV as evidence for determining the eligibility.

-

Please note that, although the term GLP is used in Schedule-1 in accordance with the practice, this schedule includes the criteria and requirements to bereferred to in the case of financing that specifies the use of proceeds, such as transition projects in the case of transition finance that specifies the use ofproceeds (PF and UoP) based on CTFH and CTFBG. Therefore, the following checklists should be read in the context of transition finance as appropriate.

-Transition finance executed by SMBC as the Enabler also includes GCP. In the assessment of GCP, the implementation of the transition strategy based on the
borrower's business activities is considered as a "project." Therefore, the term “project” in the checklists should be read as “business activity.” The GCP does
not require management of the five elements required for transition-linked finance categorised as the CTF, and no setting of finance characteristics orverification will be conducted using the trigger event(s) determination based on the setting or achievement of SPTs.

GLP-1 Use of Proceeds
Ref.

Criteria

Requirements

Work Undertaken

DNV Findings

1aTypes of funds

The types of transition loan are classified
into one of the following types defined by
GLP.
・ (Standard) Transition Loan
・ Transition Revenue Loan
・ Transition Project Loan・ Other

Confirmed documents:- Playbook- Checklists- List of TF-approved
projects

DNV has confirmed that 18 transition finance projects (period: May
2023 - February 2024) implemented by SMBC as an Enabler in thelist of TF-approved projects were classified in the following
categories:・ (Standard) Transition Loan (UoP)・ Transition Project Loan (PF)・ Other:
GCP is included as “other.”

The key to a transition loan is that theproceeds will be used for a transition
project, which should be properly stated in
the legal documents relating to thesecurity/loan.

Confirmed documents:- Playbook- List of TF-approved
projects

1b

Green/transition
Project Classification

Interviews withstakeholders

DNV has confirmed through the projects in the list of TF-approved
projects that the transition finance is intended to be used tofinance a wide range of transition projects or GCP that focus on
the realization of the environmental goals and transition strategies

Ref.

1c

Criteria

Environmental
benefits

Requirements

All transition projects to which the funds
are used should have clear environmental
benefits, the effects of which should beassessed by the borrower and, where
possible, quantitatively demonstrated.

Work Undertaken

DNV FindingsInterviews withstakeholdersof borrowers whose eligibility is assessed by SMBC as an Enabler,
as described in the Playbook.
DNV has confirmed about transition finance (PF, GCP, and UoP)
described in the list of TF-approved projects that the funds
provided through transition finance will be fully allocated to one ormore transition projects.
DNV has confirmed through the assessment that the projects
assessed for eligibility are truly environmentally beneficial astransition-eligible projects, however, it has been confirmed thatsome of the selected projects have identified uncertain elements inthe transition strategy and target setting of the borrower as
required by the Playbook and relevant documentation, and that
SMBC is committed to ongoing engagement and monitoring ofthese elements. Therefore, DNV judges that ongoing assessment
and confirmation are required to ensure the eligibility of transition
finance.

Confirmed documents:- Playbook- Internal Taxonomy- Checklists- List of TF-approved
projects

Transition projects described in the list of TF-approved projects arethose which are judged to contribute to the goals based on the
borrower’s transition strategy and contribute to decarbonizationthat have been evaluated by SMBC’s eligibility assessment
described in 1b as projects. DNV has confirmed that GCP is
expected to contribute to the decarbonization of society as a wholethrough the borrower’s transition initiatives on an appropriate
timeline. DNV has also confirmed that the environmental benefitsof both the transition projects and GCP are GHG emission
reductions, which will be assessed either quantitatively or
qualitatively by SMBC or the borrower.
However, as some of the sampled projects contained yet to be
determined elements, specifically in the borrowers’ transition
strategy and target setting compared to the requirements of the
Playbook and related documents, DNV judges that a continuous
evaluation and monitoring is necessary to ensure the eligibility totransition finance of the above-mentioned projects.

Interviews withstakeholders

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Ref.

Criteria

Requirements

Work Undertaken

DNV Findings

1dRefinancing rate

If all or part of the proceeds are used or
may be used for refinancing, the borrower
will indicate the estimated ratio of theinitial investment to the refinancing and, if
necessary. Therefore, it is recommended
to clarify which investment or project
portfolio is subject to refinancing.

Confirmed documents:- Playbook- List of TF-approved
projects

SMBC has confirmed that the borrower has indicated plans to use
the proceeds for either new investment or refinancing, or both, for
one or more of the selected project candidates.
If it is undecided, SMBC has confirmed that the borrower plans toclarify the amount of the portion of the proceeds that has been
allocated to refinancing through annual reporting.

Interviews withstakeholders

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GLP-2 Process for Project Evaluation and Selection
Ref.

Criteria

Requirements

Work Undertaken

DNV Findings

2aProject selection
process

Green/transition finance borrowers should
provide an overview of the process ofqualifying projects for whichgreen/transition finance funding will be
used. This includes (but is not limited to):・ The process by which the borrower
determines that the project in questionis included in the business category ofa qualified green/transition project.
・ Creation of criteria for eligibility of
projects for which green/transition
finance funding will be used
・ Environmental sustainability goals

Confirmed documents:- Playbook- Checklists- Internal Taxonomy

DNV has confirmed that SMBC has selected projects based on aprocess document (the outline is clearly stated in the Playbook andrelevant documentation) for determining the eligibility of projects
for which the transition finance proceeds will be used.
DNV has also confirmed that SMBC and/or the borrower considers
negative impacts associated with project implementation inaccordance with the relevant process document, that national andlocal laws and ordinances are complied with, and that assessments
based on the Equator Principles and the “SMBC Group
Environmental and Social Framework,” screening in the operationof the Playbook and Internal Taxonomy is conducted. It has been
confirmed that some of the selected projects have identified
uncertain elements in the transition strategy and target setting of
the borrower as required by the Playbook and relevant
documentation, and that SMBC is committed to ongoingengagement and monitoring of these elements. Therefore, DNV
judges that ongoing assessment and confirmation are required toensure the eligibility of transition finance.

In addition to criteria and certifications,the information published by borrowers
regarding the green/transition financeprocess also considers the quality of
performance of the borrower's frameworkand environmental sustainability.

Confirmed documents:- Playbook- Checklists- List of TF-approved
projects- Bank project
settlement
documents

2b

Borrowers'
Environmental andSocial Governance
Framework

Interviews withstakeholders

Interviews withstakeholders

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DNV has confirmed that SMBC, when selecting transition projects,
takes into consideration that, in addition to the borrower’s
transition plans being aligned with CTF, the borrower complies
with environmental laws, ordinances, and regulations regarding
the projects for which the proceeds are actually used, and thatenvironmental benefits such as GHG emission reductions are clear
either throughout the projects’ life cycle or in each process.
DNV has confirmed through the assessment of the Enabler thetransition projects implemented by the borrower are consistent
with the borrower’s transition strategies, objectives, andpathways. For those projects where the borrower’s framework was
not clear, DNV has confirmed through interviews that SMBC hadRef.

Criteria

Requirements

Work Undertaken

DNV Findings
confirmed the borrower’s framework and environment-related
performance and concluded to continue following up.

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GLP-3 Management of Proceeds
Ref.

Criteria

3a

Tracking procedure-1

3b

3c

Tracking procedure-2

Temporary holding

Requirements

Work Undertaken

DNV Findings

The net proceeds from of green/transition
finance should be managed in subaccounts, included in sub-portfolio, or
otherwise tracked. It should also be
certified by the borrower in a formalinternal process related to the borrower's
investment and financing operations for
the Transition Project.

Confirmed documents:- Playbook- Operations manuals

Through its assessment of SMBC, DNV has confirmed that SMBC
plans to confirm that the proceeds from transition finance can betracked by the borrower’s internal system and forms, and verify
the actual system and related documents in use. DNV has
confirmed that SMBC plans to confirm that the management statusof the proceeds can be proven on this basis.

During the green/transition financeredemption period, the balance of funds
raised that is being tracked should be
adjusted at regular intervals to match theamount allocated to eligible projects
undertaken during that period.

Confirmed documents:- Playbook- Operations manuals

If no investment or payment has been
made in a qualified green/transition
project, the borrower should also informthe investor of the possible temporary
investment method for the balance of
unallocated proceeds.

Confirmed documents:- Playbook- Operations manuals

Interviews withstakeholders

Interviews withstakeholders

Interviews withstakeholders

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DNV has confirmed that SMBC and the borrower plan to review thebalance of the proceeds at least once a year during the period
from the implementation of the transition finance to repayment,using internal system and forms described in 3a.

DNV has confirmed through the explanatory materials from theborrower that SMBC manages the balance of unallocated proceeds
in cash or cash equivalents.
DNV has also confirmed that SMBC plans to confirm the balance of
unallocated proceeds through the reporting from the borrower on
the allocation status of the proceeds.

GLP-4 Reporting
Ref.

Criteria

4aPeriodical Reporting

Requirements

Work Undertaken

DNV Findings

In addition to reporting on the use ofproceeds and the temporary investment of
unallocated proceeds, the issuer willconsider each project at least once a year
for projects to which the Green/transitionbond proceeds have been allocated, taking
into account the following: A list of eachproject should be provided.

Confirmed documents:- Playbook- Operations manuals

DNV has confirmed that from the time of fundraising until theproceeds are fully allocated, the borrower plans to annually reporton transition finance to SMBC or to the public and disclose theallocation status, the projects to which the proceeds have been
allocated, or information on environmental benefits.

Interviews withstakeholders- Confidentiality and competitive
considerations- Outline of each project, expected- sustainable environmental and social
effects

T

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