Exposure to coal sector: Urgewald's GCEL list, a reference for investors

Following the annual update of the Urgewald Global Coal Exclusion List (GCEL) in October 2023 (1), we conducted a series of interviews with financial markets participants, asset managers and insurers, discussing their potential use of the Urgewald GCEL in their coal sectorial policies. Overall, asset managers predominantly leverage the GCEL as a data source and watchlist, essentially to feed their in-house exclusions. They often cross-reference it with other data points from ESG agencies. Conversely, insurers use it more straightforwardly and mechanically as a whole exclusion list, while some financial supervisors refer to it as a source, notably in their questionnaire or for their modeling.

The following article encapsulates the key insights gleaned from our discussions with investors.

Urgewald is a German non-governmental organization (NGO) founded in the early 1990s, coinciding with the pivotal United Nations Conference on Environment and Development in Rio (Cop1).

For more than 30 years, Urgewald has been ‘fighting against environmental destruction and for the rights of people harmed by corporate profit interests” (1). The NGO’s final objective is to push financial companies and institutions towards divestment and exclusion of the oil & gas and coal sectors (2).  In 2017, it started to publish the so-called GCEL list.

Urgewald’s distinctive operating mode is not to stay at a generic and high-level level of discourse and public campaigning on coal exclusion or divestment. Its approach is built on three axis or assumptions: open data at firm-level across a large number of investees is fundamental (i), exposure to those sectors is rather a matter of volumes and/or percentage of activities or revenues (ii) and such exposure annually evolves, and trends are of the utmost importance (iii). Accordingly, Urgewald created an annually updated wide-scope database (the so-called “GCEL list”), which progressively imposes itself as a reference or key information resource.

Regarding data sources, Urgewald uses companies’ own reporting to extract coal-related data (websites, annual reports, financial reports, etc.) but also rely on official information provided on government-owned regional or national websites. For the coal power and mining expansion data, the information is checked with the data from Global Energy Monitor.

Subsidiaries (affiliates and joint ventures) are integrated in the analysis, based on the criteria described below.

As of 2023, the GCEL encompasses over 1,400 parent companies (and more than 1,900 subsidiaries and joint ventures) engaged in coal activities, tracing the entire value chain from exploration, mining, and extraction to production and coal gasification (3).

These companies (listed and non-listed) represent more than 90% of global thermal coal production and global coal-fired capacity. GCEL covers the whole coal universe; 65% of the companies in the list are Asian Companies (11% European EU- and Non-EU- companies and 10% from North America).

The list is today reportedly used by more than 600 financial companies according to Urgewald.

Urgewald defines 3 levels of criteria as described in the table below and the 2023 update strengthened some of the criteria.

Amongst these criteria, coal share of revenue is the most recurrent one (76% of the companies in the list meet it), following by expansion plan (49%).

We notice that 39% of the companies meet more than one criteria, showing a significant level of correlation between criteria.

Almost all investors, at least in Europe, have a coal policy in place, that defines their approach to the sector (criteria/ exclusion thresholds, exceptions, engagement practices, phase out/ transition plans, etc.).

As of today, the GCEL is the main freely available database that includes expansion plans. It is likely one of the features leading to its widespread use among financial institutions.

Among multilateral economic institutions, the International Monetary Fund (IMF) uses GCEL to calculate global coal investments for its annual report on global financial stability in April 2023. (4)

Some regulatory bodies refer to it. It is notably the case in France for the ACPR (French Prudential Supervision and Resolution Authority), overseeing banking and insurance sectors, that issues annually a questionnaire to insurance companies. In this questionnaire, insurance companies must indicate their exposure to entities listed on the GCEL, effectively gauging the collective exposure of French insurers to the coal sector. In addition, banking and financial market authorities, Banque de France and AMF use GCEL as a data source to evaluate carbon intensity of investors’ portfolios.

In the ACPR / AMF (French Financial Markets Authorities) Joint Report of October 2022 on the Monitoring And Evaluation of Climate Commitments of Paris Market Players, it is notably stated that: “In the absence of a single public list to assess an undertaking’s actual or most accurate exposure to coal, oil or gas, it has been asked to use Urgewald’s Global Coal Exit List (GCEL) for exposure to coal, and Global Oil and Gas Exit List (GOGEL) for exposure to oil and gas”.

The ACPR is aware of the methodological biases induced by the use of these two lists. According to the regulator: “The main limitation is the approach proposed by Urgewald to provide a range and not an exact figure, unlike other data providers: this choice may, in some cases, lead to high overexposure. For instance, the GCEL indicates for companies EDF or ENEL a coal share of revenue of less than 20%. This data leads, following the recommended methodology, to use the 20% figure (the upper limit) as exposure weighting, which is thus a conservative measure, while the real coal share of revenue would be less than 1% for EDF, and according to banks, around 2% for ENEL”.

Beyond regulatory bodies, some of the main European sustainable labels encourage the use of GCEL in order to be compliant with the coal criteria defined in their guidelines:

• Towards Sustainability label (Belgium # 780 funds; # €500bn in AUM): the label’s guidelines define exclusion for companies involved in harmful activities that could lead to adverse impacts on sustainability factors; for the coal sector it concerns companies involved in thermal coal prospecting and exploration, extraction/mining, processing and transportation of thermal coal with a set of criteria such as max 5% of revenues derived from these activities with an exception for transportation, for which it is 10%). The reference to Urgewald’s GCEL list as a watchlist is explicitly made and an asset manager should explain the rationale in case of investment in a company in the list. (5)

• It is also the case for the FNG label in Germany (# 257 funds; # €115 bn in AUM) that set criteria for the eligibility of thermal coal activity (e.g., coal mining < 5% revenues) and refer to the list as the reference database. (6)

• On the other hand, although the French SRI label (# 1200 funds; # €770 bn in AUM) has added new set of rules, among which coal exclusion criteria in line with those of the other labels, it does not refer to the GCEL as a reference or database to be used. (7)

In addition, the use of the list also appears among ESG data providers; In December 2023, MSCI made Urgewald’s GCEL data available through its ESG platform (as a Climate Change Metric).

MSCI focuses on expansion plans as it identifies companies expanding their coal mining activities, developing new coal power plants, or building other coal-related infrastructure-such as coal export terminals or coal railway lines.  As of today, the data have no impact on the ESG scoring or index composition.

Finally, when it comes to investors, GCEL is broadly and heterogeneously used in the design of thermal coal and power production policies, both to define their criteria but also to identify the companies in breach.

There are diverse levels of constraint on the investment universe given or attached to this list, with various use cases from mere information, criteria inspiration, to a full and mechanical use as an exclusion list; with a range of exemptions (exclusion of “GCEL constituents” except if the firm has a deemed robust transition plan).

Asset managers predominantly leverage the GCEL as a data source and watchlist, essentially to build their in-house exclusions. In many cases they are cross-referencing it with other data sources such as Carbone4 or Sustainalytics. 

Conversely to asset managers, French insurers integrate the Global Coal Exit List in a more prescriptive way, driven  by the aforementioned ACPR's annual questionnaire, compelling insurers to scrutinize the list to track their investments. Although the regulator does not mandate a blanket exclusion of the entire coal industry, the reputational impact prompts some investors to straightforwardly incorporate the list into their decision-making process.

Some actors pay greater attention to trends or dynamics - with this twin notions of expansion on the one hand, and gradual phase-out on the other hand-, with challenges around the handing of “residual” exposure over short and medium timeframes.

Following our discussion with investors, we outline two investment cases where there is no market consensus:

When a company listed on the GCEL issues a green bond for financing green use-of-proceeds (ex: Sembcorp, Albioma) it may appear as an exception of the exclusion, under the condition that the bond is aligned with the International Capital Market Association (ICMA)’s GBP principles or if the company is SBTI certified. But for other investors the coal sector policy is applied at company level whatever the format of the issuance.

It is worth mentioning that Towards Sustainability Label also contains an exception: “Use-of-Proceeds instruments issued by companies that fail the eligibility criteria can be eligible if a particular attention is given in the ESG due diligence process to these companies’ overall transition efforts.”, which is a bit vague, leaving leeway to interpretation for investors.

We can notice that reference to the issuer’s transition plan would be also consistent with guidance from the ICMA in its Climate Transition Finance Handbook. Indeed, ICMA’s guidance explicitly encourages issuers to disclose their climate transition plan or strategy, emphasizing that this should be relevant to the environmentally material parts of an issuer’s business model and that it should reference science-based targets and transition pathways. ICMA recommends that the guidance in its Handbook be applied in the application of ICMA’s Green Bond Principles, Sustainable Bond Guidelines or (SLB) Principles, where the issuer is seeking to finance a GHG emissions reduction strategy.

Different approaches also emerge, when assessing the parent company versus its subsidiaries and vice-versa. Depending on their distinct activities, subsidiaries may or may not be listed: should the entire entity be excluded, or is the exclusion limited to specific subsidiaries? This dilemma comes to the forefront when investors engage in purchasing green bonds or holding equity shares. Our discussions have highlighted diverse approaches to these structural/perimeter exceptions, with some investors opting to distinguish the parent company from its subsidiaries, while others choosing to exclude the entire group, encompassing both parent and subsidiary companies.

With great power comes great responsibility, one expects from the GCEL ecosystem ̶ composed of Urgewald itself, assessed firms which are pursuing coal related activities, and financiers acting as a final users of the list further dialogue and transparency around entity/geographical perimeter and consolidation methodology, enhanced and/or verified data sources which would improve data reliability and comparability, procedures to allowright of rectification. Meanwhile, climate-related benchmark rules as well as exclusion related criteria in labels would benefit from better interoperability with the GCEL.

The methodology would also benefit from allowing avenues to accommodate or factor regulatory constraints imposing “residual capacities” for energy security reasons in some countries. One also welcomes multi-stakeholders discussions on what sorts of exemptions to firms’ presence in this list can be more or less legitimate, particularly how transition and managed phase-out plans can be encouraged and factored.

Exit timeframes and modalities, and their subsequent net carbon footprint (which grandly varies from simply selling coal-related assets to decommissioning or repurposing them, calling for scrutiny of utilization rates and actual emissions) deserve investigation (see our editorial “2024 horizons” on transition away finance).

Dauntingly, out of the 1,433 companies on the GCEL, only 71 companies have announced coal exit dates. Meanwhile, 577 companies are still developing new coal assets