CHECKLIST FORSUSTAINABILITY-LINKED
DEBT CERTIFICATIONAPRIL 2023
Version 1.0
Accompanies the Climate Bonds Standard v4.0

The Checklist below describes more precisely what is required in order to meet the Entity Certification criteria as
described in PART D of the Climate Bonds Standard v4.0. The associated Guidance provides supporting informationthat may be useful in interpreting the Criteria and associated Checklist requirements.
Climate Bonds will also make available on its website an Excel version of the Checklist for use in Verification
Engagements.
The Checklist and Guidance have been prepared by Climate Bonds to address its specific Certification Criteria, but anumber of sources of similar guidance have informed this.1

These include but are not limited to: ACT Framework (act-framework-eng-2019-04-09.pdf (actinitiative.org), Moody’s proposed Net Zero Assessment
methodology, The Transition Plan Taskforce (TPT) Implementation guidance (TPT-Implementation-Guidance-1.pdf (transitiontaskforce.net)), GFANZ’s
Expectations for Real-Economy Transitions (Expectations-for-Real-economy-Transition-Plans-September-2022.pdf (bbhub.io) and Recommendations-andGuidance-on-Financial-Institution-Net-zero-Transition-Plans-November-2022.pdf (bbhub.io), The Transition Pathway Initiative’s methodology report:
Management Quality and Carbon Performance Version 4.0, November 2021 (90.pdf (transitionpathwayinitiative.org) (90.pdf(transitionpathwayinitiative.org), SBTi’s Net Zero Standard v1.0 (Net-Zero-Standard.pdf (sciencebasedtargets.org)), SBTi’s Target Validation Protocol (targetvalidation-protocol.pdf (sciencebasedtargets.org)), TCFD Task Force on Climate Related Financial Disclosures 2021-Metrics_Targets_Guidance-1.pdf(bbhub.io), Illustrative Examples of Selected aspects or EER Assurance Engagements under ISAE3000 https://www.iaasb.org/publications/non-authoritativeguidance-applying-isae-3000-revised-extended-external-reporting-assurance), IFRS Exposure Draft S1 General Requirements for Disclosure of Sustainabilityrelated Financial Information, (Climate Action 100+ Net Zero Company Benchmark PDF, Oct 2022) and Climate Action 100+ Net Zero Company Benchmark
PDF v1.2 Oct 2022), ICMA Climate Transition Finance Handbook, December 2020 (Climate-Transition-Finance-Handbook-December-2020-091220.pdf(icmagroup.org)) and ICMA Sustainability-Linked Bond Principles, June 2020 (Sustainability-Linked-Bond-Principles-June-2020-171120.pdf (icmagroup.org))

Criteria as written in Part D of the Climate Bonds
Standard v4.0

Certification Checklist

Additional guidance

D.1. INTRODUCTION
Eligible SLDs

Currently, SLD Certification is
only available to SLD
instruments issued by legal
entities, or segments thereof,
providing non-financial goods
and services for which the
Climate Bonds Initiative has
Climate Bonds Standard Sector
Criteria for SLD Certification

In the Climate Bonds Standard v4.0, an Entity isdefined as a legal entity, duly incorporated andvalidly existing in the jurisdiction in which it
operates, providing non-financial goods andservices or a segregated segment thereof. It may
or may not include other controlled entities(subsidiaries).
This includes:••

State-Owned Entities (SOEs) that are legal
entities with full- or partial-government
ownership established to engage in specificcommercial activities, with its own
management body, governance structure
and business planning and reporting
processes. Note, sovereigns, municipalities
and local authorities do not fall under thisdefinition of SOEs; andReal Estate Investment Trusts (REITs) where
they own or operate income-generating realestate. Note, REITs which hold financial
assets such as mortgages on real estate
property do not fall under this definition of
REITs.

D.2. ELIGIBILITY & ACCOUNTING RULES
D.2.1 Issuer
control

D.2.2. Boundaryof economic
activities

The Issuer has operational
control over the economic
activities represented by the
Climate Mitigation
Performance Targets linked to
the SLD.

The Issuer may set theboundary of the economic
activities addressed in the
Climate Mitigation
Performance Targets linked to
the SLD instrument at theirdiscretion, subject to thefollowing condition:•

Where the same economic
activity is carried out
across multiple subdivisions or subsidiaries
controlled by the Issuer,

To obtain Certification
Audited financial statements of theIssuer confirming the parentsubsidiary relationship where theIssuer is the Parent Company, or
alternative evidence may be sought
where the relationship cannot be
confirmed from the audited financial
statements.

The economic activity is considered to be
operationally controlled by the Issuer if it is abusiness segment of the Issuer.

For subsequent annual verifications
As aboveIn the absence of audited financial statements
confirming the relationship, additional evidence
may be:•Corporate documents•
Board minutes of parent/subsidiarycompanies•
Contractual arrangements•
Intra-group reporting arrangements,
policies and procedures•
Governance structures

To obtain Certification

Associates and Joint Ventures over which theIssuer has significant influence (i.e., the power toparticipate in the financial and operating policy
decisions) but not the power to control as
defined in Clause D.2.1, will be excluded fromthe boundary. Dormant companies can be
excluded/ignored.

Management representations to thiseffect have been given by theGoverning Body of the Issuer.
For subsequent annual verifications
As above

Alternatively, the economic activity is considered
as controlled by the Issuer if it is (part of) a
subsidiary company of the Issuer over which theIssuer has operational control as defined in the
GHG Protocol.

It is encouraged (but not required) that theeconomic activities represented by the Climate
Mitigation Performance Targets align with theIssuer’s reporting structure that is in accordancewith an international disclosure framework such

Criteria as written in Part D of the Climate Bonds
Standard v4.0

Certification Checklist

the Issuer must address all
instances of that activity
across all sub-divisions andsubsidiaries of the Issuer.
D.2.3. Obtaining
SLD certification

The Issuer receives a
Verification Report from an
Approved Verifier that:i. At least 90% of theeconomic activity(ies)represented by the
Climate Mitigation
Performance Targets
linked to the SLD comply
with the Climate
Mitigation Performance
Target, Delivery Strategy,
Governance andDisclosure requirements
in Clauses D.3.1, D.3.2,
D.3.3 and D.5
respectively; andii. The remaining % of theeconomic activity(ies)represented by the
Climate Mitigation
Performance Targets
linked to the SLD
instrument comply with
the Climate Mitigation
Performance Targets,
Delivery Strategy,
Governance andDisclosure requirements
in Clauses D.3.1.1.1,
D.3.1.1.2, D.3.1.2, D.3.2,
D.3.3 and D.5
respectively; andiii. The Parent Group
complies with the Climate
Safeguard and Disclosure
requirements in Clauses
D.4 and D.5 respectively;
andiv. The SLD will not matureor become callable
before the date of thefirst interim Climate
Mitigation Performance
Target to which the debt
instrument is linked.
And the Issuer supplies the
Climate Bonds Standard Board,
through the Climate Bonds
Standard Secretariat, with acopy of the Verification Reportor shares its location on a
public website, for the purposeof publishing on the Climate
Bonds Initiative website.

Additional guidanceas those developed by the Task Force on Climate
Related Disclosures (TCFD) and the International
Sustainability Standards Board (ISSB) and/ orrecognised accounting frameworks such as the
IFRS.

To obtain Certification
Demonstration of compliance with
the Certification threshold supported
by either the latest audited financial
statements and/or independently
verified/ audited management
reporting (revenue route) or audited
GHG emissions determined in linewith the GHG protocol within the last
2 years.
Compliance with all relevant ‘To
obtain Certification’ requirements
documented under Clauses D.3, D.4
and D.5.
For subsequent annual verifications
n/a

Methodology for determining compliance with
the 90% Certification Threshold
Step 1: At the discretion of the Issuer, theeconomic activities represented by the Climate
Mitigation Performance Targets linked to the SLD
must be disaggregated according to either:•
Turnover (revenue): historical revenue per
the latest audited annual financial reports
and/or independently verified/ audited
management reporting; or•
GHG emissions: determined in line with
the GHG Protocol. This assessment to be
based on emissions data that is
independently verified/audited and not
more than two years old.
Step 2: For each economic activity represented
by Climate Mitigation Performance Targets
linked to the SLD instrument that is fullycompliant with requirements in Clauses D.3 andD.5, the proportion of revenue / GHG emissions
allocated to that activity can be counted towards
the 90% Certification Threshold.
Clarifying notes:
1. Where an Issuer chooses to disaggregate
its operations by Revenue, it is requiredthat the boundary of the activities coveredby the Climate Mitigation Performance
Targets linked to the SLD instrument arealigned with the Issuer’s management andfinancial reporting structure.
2. It is required that 100% of the revenue/
emissions from the operationallycontrolled activities be included (not justthe share of revenue/ emissions per any
financial or equity control allocation)
3. Revenue/ emissions (depending on thebasis selected for disaggregation) fromany activities that cannot be assessedagainst Climate Bonds Standard entitylevel sector-specific criteria must not becounted towards the certificationthreshold. This includes revenue (oremissions) from financial activities such as
trading or investment.
4. Business operations pursuing the same
economic activity are addressedcollectively through one assessment.
5. If taking the GHG emissions route toallocation, carbon offsets or credits or
avoided emissions should not be taken into
account.
6. If taking the GHG emissions route toallocation, estimates using tools such as
the Scope 3 Evaluator to calculate scope 3
emission category(ies) are acceptable,

Criteria as written in Part D of the Climate Bonds
Standard v4.0

Certification Checklist

And if the SLB has Use-ofProceeds elements (i.e., it is ahybrid), it meets therequirements for Use-ofProceeds bonds as described in
PART A of this document.

Additional guidance
although primary data is preferable andbest practice.
See ghg-protocol-revised.pdf (ghgprotocol.org)
and Corporate Value Chain (Scope 3) Standard |Greenhouse Gas Protocol (ghgprotocol.org)

See Box D1 for the application
process for obtaining SLD
Certification.

The Issuer may opt to make publicly accessible amore concise public version of the Verification
Report, in which case the full assurance reportshall be made available to the Climate Bonds
Standard Secretariat.

A note on terminology: This
90% is defined as the‘Certification Threshold’.
To assess compliance with thisthreshold the economic
activities represented by the
Climate Mitigation
Performance Targets linked to
the SLD instrument are
disaggregated and weighted
according to either theirrevenue share or share of GHG
emissions. See the ‘SLD
Certification Checklist’
document for details on themethodology to determine
compliance.

D.2.4
Maintaining SLD
Certification

The Issuer receives an annual
Verification Report from an
Approved Verifier that:

To obtain Certificationn/a
For subsequent annual verifications

In respect of the activity(ies)represented by the Climate
Mitigation Performance
Targets linked to the SLD
instrument:
a. If, since the last
Verification Engagement,
the revenue share of any
existing part of the Issuer’s
activities that did notpreviously contribute tomeeting the Certification
Threshold increases, theIssuer has re-assessed its
compliance with theCertification Threshold andthe Certified SLD stillmeets the Certification
Threshold (per Clause
D.2.1).
b. All interim Climate
Mitigation Performance
Targets (per Clause
D.3.1.1) and all interim
milestones in the Delivery
Strategy (per Clause D.3.2)
falling due since the last
Verification Engagement
have been met. The onlyIf, since the last verification
engagement, the revenue share ofany existing part of the Certified
Entity activities that did notpreviously contribute to the Certified
Entity meeting the Certification
Threshold has increased,
demonstration of compliance with
the Certification threshold supportedby the latest audited financial
statements and/or independently
verified/ audited management
reporting.
Compliance with all the ‘For
subsequent annual verifications’requirements documented under
Clauses D.3, D.4 and D.5.

For guidance on (re)assessing compliance with
the Certification Threshold, see Clause D.2.3
Obtaining Entity Certification.

Criteria as written in Part D of the Climate Bonds
Standard v4.0

Certification Checklist

Additional guidance

To obtain Certification

Contractual obligations to Climate Bonds include,
but are not limited to, reporting requirements,
payment of the certification fee in accordancewith the Climate Bonds Certification Fee Policy.

exception to this may be
where compensatory
measures have been taken
or are planned to address
underperformance andthose measurescollectively meet therequirements in Clause
D.3.3; andc. Any and all correction
measures have been taken
to address any anticipatedunderperformance in thedelivery of the Delivery
Strategy and future interim
Climate Mitigation
Performance Targets (perClause D.3.3); andd. All disclosure
requirements have beenmet (per Clause D.5.)
and
The Parent Group remains incompliance (per Clauses D.4
and D.5)
andThe Issuer is not subject torevocation of Certification due
to any of the events detailed in
Box D2andThe Issuer supplies, throughthe Climate Bonds Standard
Secretariat, the Climate Bonds
Standard Board with a copy of
the annual Verification Reportor shares their location on a
public website, for the purposeof publishing on the Climate
Bonds Initiative website.
Box D2:
Revocation of
SLD Certification

SLD Certification will be
rescinded at any time where:
1. The Issuer becomes awarethat the Certified SLD
instrument and/ or the Parent
Group no longer conforms
with the Climate Bonds
Standard and provides a
written statement to that
effect to the Climate Bonds
Standard Secretariat; or
2. A Verification Engagement
commissioned by the Climate
Bonds Standard Board, findsthat the Certified SLDn/a
For subsequent annual verificationsn/aCriteria as written in Part D of the Climate Bonds
Standard v4.0

Certification Checklist

Additional guidance

instrument and/ or the Parent
Group no longer conforms
with the Climate Bonds
Standard; or
3. The Climate Mitigation
Performance Targets to which
the SLD instrument is linked
are reset at a level lower (i.e.
represent smaller emissions
reductions) than those in placeat the time of Certification; or
4. The Issuer has breached any
contractual obligation towards
the Climate Bonds Initiative.

D.3. TRANSITION PLAN LINKED TO THE SLD INSTRUMENT
A Transition Plan is a time-bound and trackablestrategy and roadmap presenting the plans andactions for reducing emissions to achieve thefuture Climate Mitigation Performance Targets,and the assumptions underpinning it.
It should demonstrate that the Certified Entity
has identified viable activities in a low-carbon
economy that it intends to engage in, and that
action plans and mechanisms are being put inplace to deliver the transition in line with the
Climate Mitigation Performance Targets set, andthis transition has been fully integrated into theentity’s wider business model and forward plans.
The Transition Plan must include the elements
detailed here but need not be limited to them.
However, any additional elements beyond thosedetailed here will not be within the scope of
Certification and Certification confers noassurance over them.
Specifically, performance targets linked to the
SLD instrument that relate to social goals or
biodiversity, water or other environmental goals
are not assessed under the Climate Bonds
Standard, and Certification confers no assurance
over those performance targets or any
associated (elements of a) transition plan.
D.3.1 CLIMATE PERFORMANCE
D.3.1.1. Climate
Mitigation
Performance
Targets

The Climate Mitigation
Performance Targets to which
the SLD instrument is linked
meet the following
requirements:
D.3.1.1.1. Time horizon
The Climate Mitigation
Performance Targets cover thetime from the date ofCertification to the date theactivity is intended to hit net
zero emissions, or 2050,
whichever is sooner.

To obtain Certification
Documented Climate Mitigation
Performance Targets meet therequirements laid out in Clause
D.3.1.1.
Board minutes and related
documents not older than 12 months
from the application for Certification
documenting approval of the Climate
Mitigation Performance Targets thatmeet the requirements.
The sole exceptions to this are if:

A list of the Climate Bonds Standard Sector
Criteria available for the purposes of Entity and
SLD Certification is available here. There is nocross-sectoral pathway. If criteria for a sector do
not exist, then SLD instruments with Climate
Mitigation Performance Targets representing
activities in that sector cannot be Certified,unless they form part of the % outside of theCertification Threshold per Clause D.2.2.
The Climate Mitigation Performance Targets
need not be limited to but must address all
metrics and criteria listed in the relevant climate

Criteria as written in Part D of the Climate Bonds
Standard v4.0
D.3.1.1.2. Interim Climate
Mitigation Performance
Targets
The Climate Mitigation
Performance Targets include
interim targets on a threeyearly basis for the nine years
following the date ofCertification, and a five-yearlybasis thereafter over the fulltime horizon described in
Clause D.3.1.1.1.
D.3.1.1.3. Alignment withdecarbonisation pathways of
the Climate Bonds Standard.
All interim Climate Mitigation
Performance Targets per
Clause D.3.1.1.2 representing
economic activities that
contribute to meeting theCompliance Threshold (seeClause D.2.3) are benchmarked
against the climate mitigation
criteria in the Climate Bonds
Standard Sector Criteria andalign with those criteria by 31
December 2030 at the latest.
N.B. Different levels of SLD
Certification are awarded
depending on the date the
Climate Mitigation
Performance Targets align with
the Climate Bonds Standard
Sector Criteria – see Box D4.
D.3.1.1.4. Board approval
The Board of the Issuer has
approved the Climate
Mitigation Performance
Targets no earlier than one
year prior to application for
Certification.
Box D3: Twolevels of SLD
Certification

Box D3: Two levels of SLD
Certification
Two levels of SLD Certification
are available, contingent on
when the Climate Mitigation
Performance Targets align with
the Climate Bonds Standard
Sector Criteria.
1. Level 1 – “Aligned”: The
Climate Mitigation
Performance Targets
align with the Climate
Bonds Standard Sector
Criteria at the time ofcertification andthereafter until the date
the Climate Mitigation
Performance Targets
represent net zero

Certification Checklist- The Climate Bonds Standard
Sector Criteria for Entities do notratchet down over time (i.e. thecriteria are static over time), andthe activity already meets thosecriteria.
- The Climate Bonds Standard
Sector Criteria for Entities doratchet down over time, but theactivity is already at net zero
emissions.
In these cases the requirement for
Board approval can be waived.
For subsequent annual verifications
Any interim Climate Mitigation
Performance Targets falling due
since the previous annual verification
engagement have been met.

Additional guidance
mitigation elements of the Climate Bonds
Standard Sector Criteria. These elements include
pathways of GHG emissions intensity metrics
that take into account all material scope 1, 2,
and 3 emissions, and for some activities may also
include other quantitative or qualitative
indicators and requirements. See theappropriate Climate Bonds Standard Sector
Criteria for details.
Carbon credits or avoided emissions may be
used in addition to achieving alignment with
Climate Bonds Standard Sector Criteria but
cannot be used as a means to achieve alignment
with those Criteria and do not form part of thescope of this assessment.
For a definition of the Board, see Clause D.4.1.

Or, for any interim Climate
Mitigation Performance Targets thathave not been met, corrective
actions are being taken to address
this within 12 months or by the endof the SLD instrument term,
whichever is earliest (in line with
Clause D.3.3.3).
If Climate Mitigation Performance
Targets have been reset since theprevious verification engagement (inline with Clause D.3.3.2), those reset
targets meet the ‘To obtain
Certification’ requirements above.
Board minutes document Board signoff of any reset Climate Mitigation
Performance Targets reset since theprevious verification engagement.

n/a

If less than 90% of the activities represented by
the Climate Mitigation Performance Targets
meet Level 1 requirements at the time ofcertification, but more than 90% meet Level 2
requirements, the SLD instrument is eligible only
for Level 2 certification.
If performance levels improve and Climate
Mitigation Performance Targets and Delivery
Strategy are subsequently reset during the termof Certification such that the SLD instrument
subsequently attains the 90% threshold requiredfor Level 1, then certification can be ‘upgraded’
from Level 2 to Level 1 certification. This issubject to audited verification of this improved
performance and reset Climate Mitigation
Performance Targets and Delivery Strategy thatmeet the requirements of Clauses C.3.1.1. andC.3.2 respectively.

Criteria as written in Part D of the Climate Bonds
Standard v4.0

Certification Checklist

emissions or 2050,
whichever is sooner.
2. Level 2 – “Transition”:
The Climate Mitigation
Performance Targets do
not align with the Climate
Bonds Standard Sector
Criteria at the time ofcertification but align by
31 December 2030 andthereafter until the date
the Climate Mitigation
Performance Targets
represent net zero
emissions or 2050,
whichever is sooner.
In addition, for both levels, theDelivery Strategy andgovernance for theachievement of those Climate
Mitigation Performance
Targets meet the requirements
described in Clauses D.3.2. andD.3.3. respectively, the Parent
Group complies with therequirements described in
Clause D.4 and the disclosure
requirements of Clause D.5 aremet.
D.3.1.2. Climate
Adaptation &Resilience
Performance

The economic activities of theIssuer represented by the
Climate Mitigation
Performance Targets linked to
the SLD instrument also meet
any climate adaptation andresilience requirements in therelevant Sector Criteria.

Additional guidance

Under Level 2, ‘align by 2030’ means alignment
with the thresholds of 2030 by 2030, notalignment with the thresholds at the time ofcertification by 2030.

To obtain Certification
Any requirements documented
under ‘Climate Resilience Criteria’ in
the Climate Bonds Standard Sector
Criteria

Not all Climate Bonds Standard Sector Criteria
have Climate Resilience Criteria at this time. If
this is the case, then Clause D.3.1.2. can beignored.

For subsequent annual verifications
Any requirements documented
under ‘Climate Resilience Criteria’ in
the Climate Bonds Standard Sector
Criteria

D.3.2 DELIVERY STRATEGY
D.3.2.1. Board
approval of the
Delivery Strategy

To obtain Certification
If a Delivery Strategy isrequired* for the economic
activity(ies) represented by
Climate Mitigation
Performance Targets per
Clause D.3.1.1., that Strategy:• Includes all the elements
listed in Clauses D.3.2.2.
and D.3.2.3.; and•Has been approved by the
Board of the Certified
Entity no more than one
year prior to theapplication for
Certification.
* See supplementary guidance
for the list of economic

The Delivery Strategy addresses andis tailored to all the activities
represented by the Climate
Mitigation Performance Targets
linked to the SLD instrument.
Board minutes and related
documents documenting Board
approval of the Delivery Strategy andall the supporting documents inClause D.3.2., dated within one yearof the date of the application for
Certification.
For subsequent annual verifications
Board minutes document Board
approval of any Delivery Strategy

In essence, activities for which emissions are
already near net zero do not require a Delivery
Strategy. See supplementary guidance here forthe list of activities that do/ do not require a
Delivery Strategy.
If the Delivery Strategy encompasses a numberof different economic activities, each activity
represented by the Climate Mitigation
Performance Targets linked to the SLD
instrument must be clearly addressed andidentifiable within each of the elements of the(combined) Delivery Strategy described below,
so that is it clear how the Climate Mitigation
Performance Targets for that activity will bedelivered.
For a definition of the Board, see Clause D.4.1.

Criteria as written in Part D of the Climate Bonds
Standard v4.0
activities that do/ do not
require a Delivery Strategy.
D.3.2.2
Foundations
D.3.2.2.1. Vision

The Delivery Strategy includes
the following foundational
elements.
A Vision outlining the longterm strategic objectives andpriorities for the economic
activity(ies) of the Issuer
represented by the Climate
Mitigation Performance
Targets of Clause D.3.1.1.,
including the long term vision
for its physical assets andoperating model.

Certification Checklist

Additional guidance

reset since the previous verification
engagement.

To obtain Certification
For each economic activity of theIssuer represented by the Climate
Mitigation Performance Targets, the
Vision describes:• The evolved product and/ orservice that will deliver the longterm Climate Mitigation
Performance Targets.
• The future operating model andsupporting asset base that will
underpin this.
• The associated priorities to deliver
the long-term Climate Mitigation
Performance Targets.
• Any future reliance on newtechnologies and changed
policies.

The Vision will be specific to the context of theactivities represented by the Climate Mitigation
Performance Targets linked to the SLD
instrument. Factors to be considered include
investments in low-carbon technologies, any
phasing out or other disposal of assets ofactivities that cannot be decarbonised, value
chain engagement activities, and lending orinvestment objectives.
As carbon credits or avoided emissions may not
be used to achieve alignment with Climate Bonds
Sector Criteria, the role of any carbon offsets,
carbon removals and avoided emissions theIssuer anticipates employing to address any
residual emissions over and above thoserequired to meet the Climate Bonds Sector
Criteria should be clearly demarcated.

The Vision is compatible with thelong term Climate Mitigation
Performance Targets see Clause
D.3.1.1.
The Vision is compatible withdisclosures made in sustainability
reporting and wider TCFD reportingof the Issuer. In particular, it
responds to the climate-related risks
and opportunities identified by theIssuer through TCFD reporting
processes.
For subsequent annual verifications
Any amendments to the Vision since
the previous verification engagement
meet the ‘To obtain Certification’requirements as described above.
D.3.2.2.2.
Strategic
Narrative

A Strategic Narrative describing
how each of the economic
activity(ies) represented by the
Climate Mitigation
Performance Targets will
evolve from their current
position to the Vision of Clause
D.3.2.2.1. taking into accountbusiness context.

To obtain Certification
For each economic activity
represented by the Climate
Mitigation Performance Targets
linked to the SLD instrument, theStrategic Narrative describes:
a. Current GHG emissions, inabsolute emission terms and anyother metrics such as emissions
intensity detailed in the Climate
Bonds Standard Sector Criteria.
Including information on thecurrent sources of GHG emissions
and how and by whom this has
been calculated and verified.

The content of the Strategic Narrative will be
specific to the Issuer according to their business
context, such as relevant region-specificconsiderations, organization size and market
position, operating model.
However, where the appropriate Climate Bonds
Standard Sector Criteria include key actions thatwould be required for Certification these must
be incorporated within the decarbonisation
levers of the Narrative Strategy.
Depending on the nature of the decarbonisation
lever, external evidence may include academic
studies, third party expert verification, evidence
from comparable action taken in similar
circumstances, contractual undertakings,

Criteria as written in Part D of the Climate Bonds
Standard v4.0

Certification Checklist

Additional guidanceb. The nature and timing of
decarbonisation levers to bepulled and a quantification of
their emissions reduction(identifying any potential
emissions trade-offs). These toinclude but not be limited to:i. Changes to the structure of
the Issuer, including any
organic growth, mergers
and acquisitions,divestments or retirements
ii. Changes in the Issuer’s
product and service
portfolioiii. Adoption of any newtechnologies
iv. Changes in supply chain
relationships.
c. The assumed market trends,
business growth, pricing anddemand underpinning thetransition as well as regulatoryand government policy
assumptions. This includes how
climate change risks andopportunities have been
incorporated.
d. The key internal and external risks
and barriers that the Issuer faces
and the potential impact on
specific decarbonisation levers.
e. Key sources of uncertainty inestimation, assumptions or
outcome.
f. The source and significance of any
locked-in GHG emissions.
g. How the Issuer will embed thestrategic ambition of its Transition
Plan in its wider business model,
highlighting key implications for
products and services, resourcing
and operational and capital
expenditure, acquisitions ordivestments.

government or regulator undertakings or
established market trends.

The Strategic Narrative breaks thetimeline down into 3-yearly intervals
to 2035, and a 5-yearly basis
thereafter until the earlier of thetarget date for net zero and 2050.
The decarbonisation levers arebroadly consistent with those of net
zero pathways for the sector.
The plausibility of the Strategic
Narrative is supported by external
evidence regarding the feasibility andtiming of the decarbonisation levers
and their estimated impact onemissions. Material deviations are
explained and supported. If expected

The scopes and sources of GHGs addressed in
the Climate Bonds Standard Sector Criteria must
be included in the estimation of current GHG
emissions. Methodologies to estimate emissions
must follow those outlined in the Climate Bonds
Standard Sector Criteria.
The strategy may rely on nascent or mostly
existing or incremental technology
improvements. In the former case a greater bodyof evidence is required to support theassumptions made in respect of the anticipatedresulting emissions reductions.
In particular, where the strategy relies on
nascent technologies the narrative is supported
by external assessment of the technologicalreadiness and potential emissions reductions
over time of the technology, and evidence that
exploration of the technology has started, suchas pilot projects. Strategies may not rely on nonexistent or non-proven technologies.
Where decarbonisation is dependent on
regulatory or government policy or changes in
consumer demand, assumptions are consistent
with known policies, market trends oranticipated scenarios from credible third parties.
Key growth business areas are not in
geographies with unsupportive policy and other
unsupportive conditions without addressing thecompensatory factors which override those
unsupportive conditions.
Where decarbonisation is assumed to be passive
this should be clearly indicated, and supportive
evidence provided for those external factors. For
example, for decarbonisation of the grid, via
globally recognized energy decarbonization
scenarios that take into account the plans andcommitments of those responsible for the grid.
Where decarbonisation is dependent on
reducing emissions in its value chain, evidence
will be required to support the assumed capacityof the Issuer to influence its value chain. For
example, entities may have greater influence on
their suppliers when their orders account for ameaningful share of the suppliers’ business andwhen multiple sourcing alternatives exist. A
reliance on large, publicly listed suppliers may
also facilitate the adoption of ambitious
emissions reduction compared to small and midsized companies (SMEs). Greater concentrationin the supplier base can also support value chain
decarbonization efforts as it may be easier toengage and coordinate emissions reduction
actions.
Potential emissions trade-offs might include
possible increases in short-term emissions that

Criteria as written in Part D of the Climate Bonds
Standard v4.0

Certification Checklist

Additional guidance

emissions reductions aresubstantially larger when comparedto similar measures adopted
elsewhere, reasonable explanationmust be given to justify this. Overall
the evidence base is appropriate,
complete and accurate.

result from actions that are necessary fordelivering long-term emissions reduction acrossthe operations.

Quantitative future outcomes arecalculated on the basis of the given
scenarios, assumptions, base dataand other information.

Variations in assumptions around prices, theexistence of product substitutes and regulatory
policies (e.g., subsidies for low-carbon products
or taxes on more carbon-intensive substitutes)
can materially impact the future acceptance of
low-carbon products by customers and thus raisequestions about the robustness of the Strategic
Narrative.

The timing and anticipated emissions
reductions of the decarbonisation
levers are compatible with the(interim) Climate Mitigation
Performance Targets per Clause
D.3.1.1.
The Strategic Narrative is compatible
with disclosures made insustainability reporting and any
wider TCFD reporting of the Issuer. In
particular, it responds to the climaterelated risks and opportunities
identified by the Issuer through any
TCFD reporting processes.
For subsequent annual verifications
The Strategic Narrative described iscompatible with made in any post
certification sustainability reporting
and any wider TCFD reporting of theIssuer.
Any amendments to the Strategic
Narrative since the previous
verification engagement meet the‘To obtain Certification’requirements as described above.

D.3.2.3.6.
Broader social
andenvironmentalalignment

A position statement aligning
the Vision and Strategic
Narrative of Clauses D.3.2.2.1
and D.3.2.2.2. with the Issuer’s
broader environmental andsocial objectives, strategies
and/ or policies, in particulardemonstrating that effects on
biodiversity sensitive areas,
emissions to water andhazardous waste have beentaken into account.
In addition, the Issuer is not
subject to a complaint to a
National Contact Point of theOECD regarding Responsible
Business Conduct ofMultinational Enterprises.

To obtain Certification
The position statement meets therequirements of Clause D.3.2.3.6.
This includes addressing whether,and if so how, the alignment with theIssuer’s broader environmental andsocial objectives considers any
contribution to the Just Transition in
the region in which the activities arecarried out.
Risks of negative environmental orsocial externalities related to themain actions supporting the Vision
and Strategic Narrative have been
identified and monitoring systems
are in place to monitor those risks
and escalate mitigation orcompensation measures if theexternalities materialise.

These broader environmental and social
objectives, strategies and policies should relate
to the Issuer’s ESG objectives and policies,
obligations under any sustainability reporting
requirements and/ or regulations.
At this time, this guidance does not define a Just
Transition or the requirements for how a
Delivery Strategy incorporates a Just Transition.
This can be done by the Issuer using whatever
tools, frameworks or methodologies as it deems
appropriate. As a broad definition, a Just
Transition would be the delivery of a net zeroand climate-resilient economy in a way thatdelivers fairness and tackles inequality andinjustice.

Criteria as written in Part D of the Climate Bonds
Standard v4.0

Certification Checklist

Additional guidance

Confirmation that the Certified Entity
is not subject to a complaint to a
National Contact Point of the OECD
regarding Responsible BusinessConduct of Multinational
Enterprises.
For subsequent annual verifications
Evidence that the risks of social andenvironmental externalities are being
monitored and acted upon.
D.3.2.3
Implementation
plans

Implementation plans include
the following.

D.3.2.3.1. Action
Plan for Scope 1& 2 Emissions

A time-bound plan of the
trackable actions the Issuer willtake or is taking to implement
its decarbonisation strategy as
described in the Vision andStrategic Narrative and thereby
deliver its Climate Mitigation
Performance Targets regarding
scope 1 & 2 emissions.
This includes interim
milestones and metrics
annually for the first five yearsof certification, three-yearly forthe subsequent nine years anda five-yearly thereafter.
N.B. This is only required if therelevant Climate Bonds
Standard Sector Criteria
address scope 1 and/or scope 2
emissions.

To obtain Certification
For each decarbonisation leveridentified in the Strategic Narrative
relating to scope 1 or 2 emissions,the documented Action Plan
identifies a schedule of actions (aroadmap) that will deliver that lever.
For each decarbonisation lever andassociated schedule of actions,interim milestones and business andoperational metrics are identified forthe purpose of monitoring deliveryof the Action Plan, per the schedule
described in Clause D.3.2.3.1.
The documented actions are broadly
consistent with those of peers
targeting similar decarbonisation
levers. Material deviations are
explained and supported.
The plausibility of the actions is
supported by external evidence
regarding the feasibility and timing of
the proposed action and its
estimated impact on emissions.
Collectively, the actions identified in
the Action Plan can plausibly be
expected to deliver the
decarbonisation levers described in
the Strategic Narrative.
For subsequent annual verifications
The interim milestones and metrics
falling due since the previous annual
verification engagement have beendelivered/ met.
Or, for any milestones or metrics
that have not been met, thecorrective actions being taken toaddress this within 12 months or by
the maturity of the SLD instrument,
whichever is earlier (in line with
Clause D.3.3.)

The Action Plan will be specific to the Issuer.
However, where the appropriate Climate Bonds
Standard Sector Criteria include key actions and/or business or operational metrics that would be
required for Certification these must be
incorporated into the Action Plan.
Key milestones are one-off actions to beundertaken. They must be sufficiently granularthat progress can be assessed annually.
For example, if the decarbonisation lever is the
deployment of a new technology, the Action Planshould detail the steps taken to develop anddeploy that technology, from investments in
R&D, patent registering, pilot projects, scaling
projects etc. Not simply state that thetechnology will be deployed ten years hence.
Likewise, if the decarbonisation lever is a switch
to renewable energy, the Action Plan should
detail the steps taken to source that energy,
such as intentions for and source of renewableenergy certificates (RECs) and / or purchasing
power agreements (PPAs) and as well as any
action to install and operate on-site generation.
The actions must be concrete. Vague
descriptions such as ‘accelerate our transition tocleaner energy solutions’, ‘modernize ouroperations’ or ‘leverage green solutions’ without
a description of the specific actions that will betaken, and the impact of those actions, are noteligible.
Depending on the nature of the action, plausible
evidence of the expected impact of the actions
identified in the Action Plan may include
academic studies, third party expert verification,evidence from comparable action taken insimilar circumstances, contractual undertakings.
Business and operational metrics are crosscutting targets that can be used to assess overall
progress in the implementation of the Action
Plan. For example, % of product sold that is low
carbon, % energy from renewable sources/
emissions intensity of energy used/ total

Criteria as written in Part D of the Climate Bonds
Standard v4.0

Certification Checklist

Additional guidance

Any amendments to the Action Plan
since the previous verification
engagement meet the ‘To obtain
Certification’ requirements as
described above.

emissions of energy used, % of recycled source
materials etc.
These milestones and metrics together addressand enable the tracking of all key actions
identified in the Action Plan as necessary todeliver the decarbonisation levers.
Plausible evidence of the interim actions being
taken and/ or interim metrics and milestones
being met will vary but might include
management reports, Board papers, audited
sustainability reports, public announcements,
evidence of capital expenditure or contracted
services or equipment, sales contracts.

D.3.2.3.2. Action
Plan for Scope 3
Emissions

A time-bound plan of the
trackable actions the Issuer willtake or is taking to implement
its decarbonisation strategy as
described in the Vision andStrategic Narrative and thereby
deliver its Climate Mitigation
Performance Targets regarding
scope 3 emissions.

To obtain Certification
The documented Action Plan
describes:

i. Clear objectives for value chain
engagement that align with value
chain related decarbonisation
lever(s) identified in the Strategic
Narrative. These objectives
address the desired behaviours orThis includes interim
results or outputs from value
milestones and metrics
chain partners, and the expectedannually for the first five years
contribution to the delivery of theof certification, three-yearly forrelevant decarbonisation lever(s).
the subsequent nine years and ii. The granular actions to be taken
a five-yearly thereafter.
to achieve these objectives, withidentified trackable interim
N.B. This is only required if themilestones and metrics to enable
relevant Climate Bonds
the monitoring and assessment ofStandard Sector Criteria
progress per the schedule
address scope 3 emissions.
described in Clause D.3.2.3.2.
iii. An escalation process andmitigation action that will betaken should value chain
stakeholders show little orinsufficient response toengagement and/ or interim
milestones and metrics are notmet. In particular, if the plan isfully or partially reliant on
partners setting their own
compatible emissions reduction
targets, it is accompanied by amechanism for assessing theveracity of any partner emissions
reduction claims and a
description of and timeframe forthe compensatory action that will
be taken if partners do not set or
achieve their own emissions
targets.
The timing and anticipated emissions
reductions of the engagement
actions described in the Action Planfor Scope 3 emissions can plausibly

The Action Plan for Scope 3 emissions is aroadmap for engagement with downstream andupstream entities in the Issuer’s value chain e.g.
suppliers, distributors, final customers andportfolio companies.
The Action Plan should identify avenues throughwhich the Issuer has significant influence on their
suppliers or customers.
Appropriate actions and associated milestones
and metrics will vary by Issuer. Examples
include:- % of procurement from no- or low GHG
suppliers.
- Implementing a sourcing governance policy
or framework ensuring new supply chain
partners are compatible with the objectives
described in the Action Plan for Scope 3
emissions.

Criteria as written in Part D of the Climate Bonds
Standard v4.0

Certification Checklist

Additional guidance

be expected to deliver the associateddecarbonisation levers identified in
the Strategic Narrative.
For subsequent annual verifications
The interim milestones and metrics
falling due since the previous annual
verification engagement have beendelivered/ met.
Value chain partners brought onsince the development of any low
carbon procurement policy or similar
have been comply with the terms ofthat policy. This may be evidenced
via contractual agreements withthose partners.
Any amendments to the Action Planfor Scope 3 emissions since theprevious verification engagement
meet the ‘To obtain Certification’requirements as described above.
D.3.2.3.3.
Finance plan

A Finance Plan detailing thefinancial implications of theStrategic Narrative and Action
Plans, and the trackable actions
being taken/ to be taken todeliver this Finance Plan.
This includes interim
milestones and metrics
annually for the first five yearsof certification, three-yearly forthe subsequent nine years anda five-yearly thereafter.

To obtain Certification
The Finance Plan for the delivery of
the Climate Mitigation Performance
Targets addresses:
-

-

-

-

The costs (CapEx and potentially
OpEx), revenue impacts andother balance sheet impacts ofimplementing the Strategic
Narrative and associated Action
Plans.
The planned sources of funding
to cover these costs.
An assessment of how thefinancial impacts describedabove will impact the overall
financial metrics of the Issuer
and any implications for theongoing financial viability of theIssuer.
Identification of metrics thathave significant estimation
uncertainty, noting the sources
and nature of the estimation
uncertainties and the factors
affecting the uncertainties.
Financial milestones and target
metrics that can be monitored
to track progress in the deliveryof the Finance Plan per theschedule described in Clause
D.3.2.3.3.

This Finance Plan incorporates
detailed financial budgets for firsttwo years. Higher level estimates andprojections may be used over thesubsequent three to five years.
Beyond that, estimates andprojections will be broader and into
the longer term represent more a

The details of the Finance Plan will be specific to
the Issuer. However, the following guidance
applies to all.
Financial considerations typically have greater
bearing for sectors that are capital-intensive or
where transition is expected to involve verysignificant investments and costs. Issuers whosetransition to lower emissions does not entail
significant costs would likely provide fewer
details on financial strategy.
Costs relate to the investments (CapEx) andoperational costs (OpEx) needed to deliver the
Climate Mitigation Performance Targets.
Examples include R&D or investment costs in
new technologies or infrastructure, site
remediation, contract penalties, regulatory costs,
restructuring costs, higher supplier prices arisingfrom the transition, long-term utilities savings
from investment in renewable energy assets.
They must address all current, committed andanticipated impacts.
Revenue impacts must include the positive
and/or negative impacts from changed productor service offerings and/ or the prices of thoseofferings.
Balance sheet impacts must address balance
sheet and cash flow impacts. For example
revised asset values/ write-downs.
Target metrics that can be tracked over timemight include:- % of the Issuer’s capital expenditure alignedwith the Strategic Narrative and Action Plans- % of the Issuer’s R&D aligned with theStrategic Narrative and Action Plans- % of the Issuer’s asset base aligned with the
products/ services described in the Vision

Criteria as written in Part D of the Climate Bonds
Standard v4.0

Certification Checklist

Additional guidance

broad conceptualization of possible
financial pathways.

- % of the Issuer’s revenue aligned with the
products/ services described in the Vision.

The costs estimated in the Finance
Plan are reasonably sized compared
to sector peers and/ or the overallplausibility of the Finance Plan is
supported by external evidence fromcredited third party sources. Material
deviations are explained andsupported. If expected costs orrevenue impacts are substantiallydifferent when compared toequivalent estimations elsewhere,reasonable explanation is given tojustify this.
Assumptions on growth, market
demand for products, prices andcosts related to future business mix
are broadly aligned with industry
trends, and the plan adequately
justifies an expectation ofcommercial viability.
Quantitative future outcomes arecalculated on the basis of given
scenarios, assumptions, base dataand other information and reflect
the uncertainties and sensitivities
identified in the Strategic Narrativeand Sensitivity Analysis.
The selected milestones and target
metrics are clearly linked to thedelivery of the Finance Plan andrepresentative of all aspects of it andcan be tracked over time.
There is no material uncertainty
related to the capacity of the Issuer
to finance the transition represented
by the Climate Mitigation
Performance Targets, either due tolikely underestimation of costs or
weak financial profile compared tothe expected expenditures involved,
estimated sources of finance, andtheir timing.
The Issuer’s projected asset basedoes not indicate a lock-in to highcarbon impact technologies that isinconsistent with the attainment of
the Vision and Strategic Narrative.
Financial data and assumptions are
consistent with and integrated into
the corresponding financial data andassumptions in the Issuer’s financial
statements in accordance with therelevant accounting standard.
For subsequent annual verifications

Criteria as written in Part D of the Climate Bonds
Standard v4.0

Certification Checklist

Additional guidance

The interim milestones and target
metrics falling due since the previous
annual verification engagement havebeen delivered/ met.
Or, for any milestones or target
metrics that have not been met, thecorrective actions being taken toaddress this within 12 months or by
the maturity of the SLD instrument,
whichever is earlier (in line with
Clause D.3.3.).
The Financial Plan is compatible withany financial statements issued post
certification.
Any amendments to the Financial
Plan since the previous verification
engagement meet the ‘To obtain
Certification’ requirements as
described above.
D.3.2.3.4.
Internal policyalignment

Information on the key internal
policies and conditions
developed or to be developed
to enable the delivery of the
Climate Mitigation
Performance Targets, Strategic
Narrative, Action Plans andFinance Plan, explaining howeach of these policies supports
specific elements andmilestones in the Strategic
Narrative, Action Plans andFinance Plan.

To obtain Certification
Documentation of the key internal
policies that need to be developed todeliver the Climate Mitigation
Performance Targets.

Key policies and conditions will vary according to
the Issuer and its activities. They may cover
operational, financial or any other aspects of thetransition.

For each policy, the following is
described:--

The objective of the policy
The activity to which it relates
How it supports the delivery of
the Climate Mitigation
Performance Targets, linking it
to elements in the Strategic
Narrative / Action Plans and/or Finance Plan
A schedule for its development
and implementation, withannual trackable milestones.

For subsequent annual verifications
The trackable milestones have been
met.
Or, for any trackable milestones thathave not been met, an explanation is
given of how this will not affect thedelivery of the Action Plan/ Finance
Plan/ Climate Mitigation
Performance Targets, or corrective
actions have been identified and arebeing implemented to address thisunderperformance within 12 months
or by the maturity of the SLD
instrument, whichever is earlier (inline with Clause D.3.3.).
D.3.2.3.5.
Sensitivity
analysis

Sensitivity Analysis identifying
the key sensitivities and risks to
the Vision, Strategic Narrative,
Action Plans and Finance Plan
that have the potential to

To obtain Certification
The key sensitivities and risks aroundkey assumptions underpinning the
Vision, Strategic Narrative, Action

Key sensitivities and risks will be specific to theIssuer, depending on their activity, size andlocation among other factors. At a minimum,

Criteria as written in Part D of the Climate Bonds
Standard v4.0
decisively impact the deliveryof the Climate Mitigation
Performance Targets.

Certification Checklist

Additional guidance

Plans and Finance Plan andultimately the delivery of the Climate
Mitigation Performance Targets are
identified.

consideration should be given to key sensitivities
and risks relating to:

Sensitivity analysis has been
performed on plausible variations ofthese key assumptions and theimpacts of these are quantified in
respect of estimated impacts on thelikelihood, timing and/ or costs ofdelivery of the Climate Mitigation
Performance Targets.
For subsequent annual verifications

•
•
•

•

-

•
•

Policy and regulatory change e.g., howpolicy and regulatory change will subsidise
the cost of investments.
Technological developments e.g., relianceon new technologies and the timing andcost of their roll out
The physical impacts of the current andforecast changing climate e.g., howchanging precipitation patterns and may
impact access to water required for
operations.
Shifts in client and consumer demand e.g.
the level of demand for products orservices that the company is not currently
providing.
Operating environment change e.g.,
decarbonisation of the grid.
Supply chain considerations e.g.,
scarcity/prices of key inputs

D.3.3. GOVERNANCE
The following accountability
mechanisms are in place togovern the delivery of the
Climate Mitigation
Performance Targets per
Clause D.3.1.1. and theassociated Delivery Strategy
per Clause D.3.2.
D.3.3.1. Boardand senior
executive
responsibility

D.3.3.1.1. Board mandate
The Board (or equivalent
governance body) has a clear
mandate to:
•

•

•

•

Oversee the selection of
the Climate Mitigation
Performance Targets anddesign of the Delivery
Strategy; andApprove the Climate
Mitigation Performance
Targets and Delivery
Strategy; andOversee the execution
and monitor progresswith the Delivery
Strategy; andApprove and monitor
any corrective actions
required where interim
Climate Mitigation
Performance Targets andDelivery Strategy
milestones are not beingmet.

D.3.3.1.2. Senior management
responsibility

To obtain Certification
The Terms of Reference, mandate
and related policies for the Board (orequivalent governance body) of theIssuer reflect the four elements
noted in Clause D.3.3.1.
There is a named board member or
executive with explicit responsibility
for the Issuer’s response to climatechange.
This person has climate change
expertise and/ or the Board engages
external experts to advise on climate
and other related technical matters.
Board minutes document receipt anddiscussion of regular status reportson the design of the Delivery
Strategy, execution of the Delivery
Strategy, and corrective measuresneeded in respect of delivery of the
Climate Mitigation Performance
Targets and Delivery Strategy, as per
the disclosed information on thefrequency of Delivery Strategy
review and monitoring.
For subsequent annual verifications

The Board or equivalent governing body means:• The Board• A named, specific, Board committee• An executive or committee that reports on
this directly to the Board or to a Board-levelcommittee.

Criteria as written in Part D of the Climate Bonds
Standard v4.0

D.3.3.2.
(Re)setting andmonitoring the
ClimateMitigation
Performance
Targets andDelivery Strategy

Certification Checklist

Senior management has
responsibility for execution of
the Delivery Strategy, and the
responsible parties haveauthority and access toresources to ensure execution.

Board minutes since the previous
verification engagement document
receipt and discussion of regular
status reports on the design of the
Delivery Strategy, execution of the
Delivery Strategy, and corrective
measures needed in respect ofdelivery of the Climate Mitigation
Performance Targets and Delivery
Strategy, as per the disclosed
information on the frequency ofDelivery Strategy review andmonitoring.

D.3.3.2.1. (Re) setting Climate
Mitigation Performance
Targets and the Delivery
Strategy

To obtain Certification

Tools and mechanisms are inplace for the (re)setting ofrobust Climate Mitigation
Performance Targets and the
Delivery Strategy, including afull review and, if necessary,
update of the Climate
Mitigation Performance
Targets and Delivery Strategy
at least every five years.
D.3.3.2.2. Tracking andmonitoring delivery
Tools and mechanisms are inplace for tracking andmonitoring of delivery ofinterim Climate Mitigation
Performance Targets and themilestones and metrics
identified in the Action Plans
and Finance Plan.

An internal control system is in placein relevant internal assurancefunctions in which there is:
1. A documented process for (re)setting the Climate Mitigation
Performance Targets and the
Delivery Strategy at least every
five years, including identificationof internal controls established toprevent, or detect and correct
inappropriate or erroneous
inputs, or computational errors in
the compilation of the financeplan, and ensure the underlying
base data is complete andaccurate.
2. An information system forobtaining, processing andcommunicating relevant dataand information of sufficientquality to enable monitoring of
progress in the delivery of theinterim Climate Mitigation
Performance Targets andinterim milestones and target
metrics identified in the Action
Plans, and the ongoingappropriateness of theassumptions underpinning the
Vision and Strategic Narrative,
including those highlighted in
the Sensitivity Analysis as posing
significant risks to the deliveryof the Delivery Strategy.
3. A central record of and tracking
processes for Interim Climate
Mitigation Performance Targets
and interim milestones andmetrics for monitoring
purposes.
4. Stakeholder communication andengagement and feedback
mechanisms.
5. An escalation process to enable
any challenges or concerns inrelation to the Issuer’s transition
to be communicated to andAdditional guidanceThis internal control system may include aninternal audit system.
Climate Mitigation Performance Targets should
be reset and/ or Delivery Strategies adjusted, as
needed, to reflect significant changes within or
external to the business that could compromise
relevance and consistency of the existing target
or delivery strategy. This re-evaluation andrecalibration must reflect changing operating
conditions and market developments, such as
new technologies coming online sooner than
expected.
Any Climate Mitigation Performance Targets
and/ or Delivery Strategy reset during the periodof Certification must comply with the Standard(including Climate Bonds Standard Sector
Criteria) in force at the date of initial
Certification, not the Standard in force at thetime of reset.
Tracking and monitoring processes should be
adequate to identify in a timely manner:- Actual underperformance against the interim
Climate Mitigation Performance Targets
and the milestones and metrics identified
in the Delivery Strategy- Anticipated underperformance of futureinterim Climate Mitigation Performance
Targets and milestones and metrics
identified in the Delivery Strategy due tochanges in internal or external factors thatmight impact on future delivery.
- Changes in anticipated operating conditions
that might conversely enable a tightening
or strengthening of Climate Mitigation
Performance Targets and associated updateof the Delivery Strategy.

Criteria as written in Part D of the Climate Bonds
Standard v4.0

Certification Checklist

Additional guidanceconsidered by senior
management and the Board as
appropriate.
Evidence that the development of
the Climate Mitigation Performance
Targets and Delivery Strategy on
which Certification has beenobtained have followed this internal
control process.
A public statement by the managing
body or executive management
committing to review the Climate
Mitigation Performance Targets andDelivery Strategy at least every 5
years, and notification of the nextscheduled review.
For subsequent annual verifications
Evidence of regular overallmonitoring of the internal control
system to determine that suchcontrols are effective.
Any Climate Mitigation Performance
Targets reset since the previous
verification engagement are incompliance with the requirements ofClause D.3.1 and supported by a(revised) Delivery Strategy thatcomplies with Clause D.3.2.
Any Climate Mitigation Performance
Targets reset since the previous
verification engagement are notweaker (i.e. represent lower
emissions reductions) than those inplace at the time of Certification.
D.3.3.3.
Correction ofunderperformance

In the event that interim
Climate Mitigation
Performance Targets andmilestones and metrics due
during the period of
Certification have not beenmet, corrective action must be
taken to reverse that underperformance, so no Climate
Mitigation Performance Target
or milestone is unmet for aperiod longer than 12 months
or by the maturity of the SLD
instrument, whichever isearlier.

To obtain Certificationn/a
For subsequent annual verifications in the event of underperformanceonly
A unified dashboard underpinned bya single system of record to track all
instances of underperformance andtheir associated action or mitigationplans.
The corrective actions are deemed to
be feasible and sufficient to correct
the performance gap.
The corrective actions are approved
and subsequently monitored by the
Board.

D.4. COMMITMENTS OF THE PARENT GROUP
D.4.1. Exclusions

Climate Mitigation Performance Targets andmilestones may be reset as part of this corrective
process (i.e. resetting Climate Mitigation
Performance Targets and/ or Delivery Strategies
can be the corrective action), but any revised
Climate Mitigation Performance Targets and/ orDelivery Strategy must be in compliance with therequirements of Clauses D.3.1.1 and D.3.2.

Criteria as written in Part D of the Climate Bonds
Standard v4.0
D.4.1.1.
Expansion offossil fuelactivities

D.4.1.2.
Conversion ofhigh carbon
stock land

D.4.2. Net zerocommitment

Certification Checklist

Additional guidance

If any legal entity within the
Parent Group is in the businessof the exploration or extractionof fossil fuels, or is a utility
company generating or
supplying power or heatgenerated from fossil fuels,then the Parent Company has,within the last year, publicly(re)committed to no expansionof any of the following
activities across the Parent
Group after 1 January 2023:
i.
The exploration andextraction of
conventional andunconventional fossil
fuel reserves; andii.
The exploration of
new conventional
and unconventional
fossil fuel resources;andiii.
Natural gas
production; andiv.
Refining crude oil toproduce derivative
products; andv.
The supply and/or
use of fossil fuels for
power generationand heat.

To obtain Certification

These activities include unconventional sources
such as hydraulic fracking, arctic drilling, oilsands and shale deposits.

The Parent Company has,within the last year, publicly(re)committed that as of 1
January 2020 no entity within
the Parent Group has or will
convert, fragment orunsustainably intensify
operations on high-carbon
stock land leading to the loss of
its status as high-carbon stockland.

To obtain Certification

The Parent Company has
approved and made public net
zero emissions commitments
covering all material scope 1, 2
and 3 emissions of the entire
Parent Group, or already has
net zero emissions as
determined in line with the
GHG Protocol and based onemission data that is
independently verified/audited
and not more than 2 years old.

To obtain Certification

Commitment documented in a
published policy or statement.
For subsequent annual verifications
Commitment documented in a
published policy or statement.

No expansion means no additional commitmentof CapEx for the acquisition or leasing of new
fossil fuel assets. These assets might be fixed(e.g., property, plant, equipment) or intangible(e.g., goodwill, capitalized licences).
Already committed CapEx with pre-dated Board
sign off is not included in the exclusion.
Capex for maintenance of existing fossil fuelassets is permitted, so long as it does not extend
the life of those assets.

Commitment documented in a
published policy or statement.
For subsequent annual verifications
Commitment documented in a
published policy or statement.

Commitment documented in a
published policy or statement.
For subsequent annual verifications
Commitment documented in a
published policy or statement.

High-carbon stock land is defined as:i. Wetlands: land that is covered with orsaturated by water permanently or for asignificant part of the year; andii. Continuously forested areas: land spanningmore than one hectare with trees higher
than five metres and a canopy cover ofmore than 30 %, or trees able to reachthose thresholds in situ; andiii. Land spanning more than one hectare withtrees higher than five metres and a canopy
cover of between 10 % and 30 %, or trees
able to reach those thresholds in situ.
The commitment must cover reducing (without
the use of offsets) material scope 1, 2 and 3
emissions to zero or to a residual level that is
consistent with reaching net-zero emissions at
the global or sector level in eligible 1.5°C
scenarios or sector pathways and neutralizing
any residual emissions at the net-zero target
date and any GHG emissions released into theatmosphere thereafter (offsets may be utilised
to address these residual emissions only).
All relevant GHGs required as per the Kyoto
Protocol (CO2, CH4, N2O, HFC, PFC, SF6, NF3)
must be included.
Materiality is defined as at least 95% of groupwide scope 1 and 2 emissions. Plus, forCriteria as written in Part D of the Climate Bonds
Standard v4.0

Certification Checklist

Additional guidancecompanies with scope 3 emissions that are atleast 40% of total emissions (scope 1, 2, and 3
emissions), at least 90% of scope 3 emissions.

D.4.3. Transition
plan

The Parent Company has
approved and made public
corresponding Transition Plans
to support the public net zerocommitment for the Parent
Group (per Clause D.4.2).

To obtain Certification
A documented, public Transition Planfor the Parent Group, aligned with
the net zero commitment, that
includes:i. The nature of the economic
activities undertaken by eachlegal entity within the Parent
Group and their respective
contribution to the Parent
Group’s total emissions andrevenue. This includes theactivities of the Certified Entity.
ii. The GHG reduction targets of allparts of the Parent Group not
represented by the Climate
Mitigation Performance Targets
linked to the SLD instrument.
This must include the target
date(s) by which each activity is
set to achieve net zero
emissions, and interim targets
for each activity over the short,medium and long term alignedwith that target. These targets
must address all material scope
1, 2 and 3 emissions.
iii. If any part of the Parent Grouppractices any of the activities
described under Clause D.4.1.1.,
the plans to fully cease those
activities by the earlier of:a. a ten-year timeframe,
andb. 2030 if located in anOECD country or 2040
elsewhere.

Materiality is defined as at least 95% of groupwide scope 1 and 2 emissions. Plus, forcompanies with scope 3 emissions that are atleast 40% of total emissions (scope 1, 2, and 3
emissions), at least 90% of scope 3 emissions.

For subsequent annual verifications
Any amendments or updates to theTransition Plan since the previous
verification engagement meet the‘To obtain Certification’requirements.
D.5. DISCLOSURE
D.5.1.
Information todisclose

The Issuer publishes and keeps
accessible on their website theinformation presented in Table
D1.

To obtain Certification
All items under the ‘To obtain
Certification’ column of Table D1
have been publicly disclosed in linewith the format of disclosure
requirements in Clause D.5.2.
For subsequent annual verification

There are no specific requirements regarding
where the disclosure items per Table D1 should
be disclosed, so long as they are publicly
available and remain publicly available via the
Applicants’ website at a minimum.
Examples: Annual reports, sustainability reports,
websites.
In respect of Transition Plan disclosures per
Table D1, the same corporate reporting norms

Criteria as written in Part D of the Climate Bonds
Standard v4.0

D.5.2. Format ofdisclosure

Disclosures have been and will
be made according to thecustomary practices regarding
corporate disclosures, such as
via annual reporting, dedicatedsustainability reporting,statutory filings and investor
presentations, at the discretionof the Issuer.

Certification Checklist

Additional guidance

All items under the ‘For subsequentannual disclosure’ column of Table
D1 have been publicly disclosed inline with the format of disclosure
requirements in Clause D.5.2.

should be applied as are applied to general
purpose financial reporting. Specifically, any
information should be disclosed that, if omitted,
misstated, or obscured, could reasonably be
expected to influence the decisions that the
primary users of general purpose financial
reporting make on the basis of that reporting.

To obtain Certification-

Disclosure integrates with, and build from,broader climate related disclosures in thereporting entity’s general purpose financial
reports.

For subsequent annual verification-