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Consideration of accreditation proposals – Addendum I Re-accreditation assessments
The document details the re-accreditation reviews for three international entities: the Asian Development Bank (ADB), the European Bank for Reconstruction and Development (EBRD), and the United Nations Environment Programme (UNEP). All three entities are recommended for re-accreditation without conditions. ADB and EBRD are recommended for 'large' project sizes and 'high risk' (Category A/I-1) environmental and social (E&S) risk categories. UNEP is recommended for an upgrade to 'medium' project size and maintains a 'medium risk' (Category B/I-2) E&S category. The assessments cover fiduciary standards, E&S safeguards, gender policies, and the entities' overall climate portfolios, noting that all three have aligned their strategies with the Paris Agreement and GCF's 2020–2023 Strategic Plan.
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Document type: Report
東アフリカ原油パイプライン(EACOP)事業による三井住友銀行への重大なリスクについて
The document argues that SMBC's involvement in the EACOP project contradicts its own environmental and human rights commitments, exposing the bank and its directors to litigation, reputational damage, and stranded asset risks. It details specific human rights abuses and environmental threats associated with the pipeline and demands a full withdrawal from the project.
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Document type: Statement
Significant risks to SMBC from East African Crude Oil Pipeline (EACOP) project
The document argues that SMBC's reported role in the EACOP project exposes the group to reputational, financial, and legal liabilities, while contradicting its own environmental and human rights commitments.
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Document type: Statement
Report on the activities of the Independent Integrity Unit
The Independent Integrity Unit (IIU) report for the period of 16 April to 17 June 2022 details the opening of eight new cases, including four project-related and three staff misconduct cases. The Unit is advancing its operational framework through the development of an Investigation Manual, an Integrity Risk Rating Tool, and a Good Practice Guide for climate-financed projects. Key policy work includes updating Fiduciary Standards and developing secondary documents for the Administrative Remedies and Exclusion (ARE) Policy. The IIU also expanded its cooperation with 32 Accredited Entities via Memoranda of Understanding and participated in international forums on corruption and money laundering.
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Document type: Report
McVeigh v. Retail Employees Superannuation Trust
The case involved Mark McVeigh, a member of the Retail Employees Superannuation Trust (REST), who alleged that the fund violated the Corporations Act 2001 and the Superannuation Industry (Supervision) Act 1993 by failing to provide information on climate change business risks and lacking a sufficiently developed climate policy. McVeigh argued that a prudent trustee should ensure investment management and risk disclosure comply with Task Force on Climate-related Financial Disclosures (TCFD) recommendations. The Federal Court of Australia recognized the litigation as being of a "public interest nature" due to the socially significant role of superannuation trusts regarding climate change. The parties reached a settlement on 2 February 2010, where REST acknowledged climate change as a "material, direct and current financial risk" and committed to implementing strategies to manage these risks and pursuing a net-zero carbon footprint by 2050 in line with TCFD.
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Document type: Legal commentary
Matters related to accreditation: report on the analysis of the accredited entity portfolio
The report assesses the GCF's network of 113 accredited entities (AEs), evaluating their capacity to deliver on the Fund's strategic priorities. While the network is diverse and expanding—particularly in private sector and direct access entities—significant gaps remain in the ability of direct access entities (DAEs) to manage high environmental and social (E&S) risk projects and large-scale adaptation programming. The analysis highlights a low AE-to-project ratio, which may disincentivize institutional capacity building, and notes that GCF's internal processing capacity is currently insufficient to meet the growing volume of new and re-accreditation applications.
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Document type: Report
Assessing the Climate Action Investment Practices of Canadian Community Foundations
The report finds that while Canadian community foundations (CCFs) have grown their endowments to nearly CAD 7 billion as of 2020, they have largely failed to use these assets to combat climate change. Most CCFs rely on vague 'ESG integration' for risk mitigation rather than pursuing climate-positive investments. The analysis reveals significant capacity gaps and a lack of diversity on investment committees, which often act as barriers to strategic change. The report recommends moving toward positive screening, increasing transparency of holdings, and joining the Canadian Philanthropy Commitment on Climate Change to align financial assets with community climate goals.
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Document type: Report
Report on the activities of the Independent Integrity Unit
The Independent Integrity Unit (IIU) report details its activities from September 2021 to February 2022, focusing on investigations, policy implementation, risk assessment, capacity building, and awareness raising. Key achievements include the implementation of a Case Management System, the approval of Investigation Standards, and the launch of a thematic brief on avoiding maladaptation at COP26. The IIU also reported on case statistics, including the dismissal of a senior manager for misconduct, and the development of an integrity risk rating tool for projects.
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Document type: Report
Enhancing the capacities of Banco de Desarrollo de Ecuador B.P. (BDE) to support its accreditation to the Green Climate Fund
The proposal seeks USD 301,717 over 12 months to help the Banco de Desarrollo de Ecuador B.P. (BDE) overcome fiduciary and technical gaps required for GCF accreditation. Implemented by the Inter-American Institute for Cooperation on Agriculture (IICA), the project focuses on updating environmental and social risk management systems, developing gender and indigenous peoples policies, and establishing a coordination mechanism to align BDE's activities with Ecuador's National Determined Contributions (NDCs) and National Climate Financing Strategy (EFIC). It also includes regional knowledge sharing with other development banks in Latin America and the Caribbean.
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Document type: Report
Sustainability Disclosure Requirements and investment labels
ClientEarth supports the FCA's proposed SDR and labelling framework in principle but warns that without strict criteria and enforcement, the regime could formalise greenwashing. The organization advocates for the adoption of 'double materiality' in disclosures, the removal of the 'Responsible' label, and the refinement of the 'Sustainable-Transition' label to avoid confusion with climate-specific terminology. It further calls for mandatory sustainability impact metrics and a clear enforcement roadmap to ensure accountability for fund managers.
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Document type: Statement
Climate-Washing Litigation: Legal Liability for Misleading Climate Communications
The report defines 'climate-washing' as a subset of greenwashing specifically targeting climate change claims and examines the rising trend of litigation used to hold state and non-state actors accountable. It categorizes misleading communications into three areas: corporate/governmental commitments (such as net-zero pledges), product attributes (such as labeling natural gas as 'clean'), and the disclosure of financial risks and investments. The authors highlight a gap between public climate pledges and actual emission reductions, noting that many companies continue to invest in fossil fuels while advertising clean energy. The document provides recommendations for companies, policymakers, NGOs, and lawyers to combat disinformation and increase transparency.
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Document type: Research paper
Report on the activities of the Independent Integrity Unit
The Independent Integrity Unit (IIU) report details activities from June to September 2021, focusing on the launch of a new case management system, the closure of nine cases, and the provision of 10 policy advisories. The unit is currently developing secondary documents to operationalise the Administrative Remedies and Exclusion (ARE) Policy and updating the 'Transparency and Accountability' section of the Initial Fiduciary Principles and Standards. Additionally, the IIU expanded its cooperation with Accredited Entities, signing four new Memoranda of Understanding, and participated in Stockholm World Water Week to discuss the nexus between climate finance and corruption.
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Document type: Report
Independent Synthesis of the Green Climate Fund’s Accreditation Function
The Independent Evaluation Unit (IEU) finds that the GCF's accreditation function is overburdened by contradictory goals and lacks a formal strategy, leading to protracted processing times and a project portfolio heavily skewed toward international entities. While the GCF prioritizes direct access, many direct access entities (DAEs) struggle with capacity and have not successfully accessed funds. The report recommends strengthening the governance of the Accreditation Committee and Panel, establishing clear business standards for processing, and implementing a project-specific assessment approach (PSAA) to improve efficiency.
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Document type: Report
Recommandations à l’ACPR et l’AMF
The document urges French financial regulators (ACPR and AMF) to implement stricter oversight of fossil fuel financing, combat greenwashing in ESG products, and integrate climate risks into prudential requirements and fiduciary duties to align the financial sector with a 1.5°C trajectory.
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Document type: Statement
Accountability Emergency
ClientEarth's review of 250 large UK-listed companies reveals a systemic failure to provide material climate-related financial information, with only 4% including such factors in financial accounts and 4% of auditors explicitly addressing them. While narrative risk disclosures are improving, they are often boilerplate. The report recommends mandatory TCFD-aligned reporting, stronger regulatory enforcement to prevent 'greenwash', and increased investor stewardship.
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Document type: Report
Increasing national capacity to adapt to climate change through enhanced finance institutions, access to localized climate information and improved climate smart investment frameworks
The proposal requests USD 322,450 over 12 months to enhance Serbia's climate adaptation capacity. It focuses on three components: aligning the Development Fund of the Autonomous Province of Vojvodina (DFAPV) with GCF fiduciary and environmental standards, creating a 'Green Navigator' platform to engage the private sector, and developing a Climate Smart Agriculture/Food Industry Investment Plan including two bankable concept notes.
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Document type: Report
Readiness Support for accreditation gap assessment, capacity building and pipeline development for potential accredited entity
The proposal requests USD 254,007 over 24 months to support the R2E2 Fund's aspiration to become a GCF-accredited entity. The project focuses on two main outcomes: strengthening the fund's institutional capacity to meet GCF Fiduciary Standards—including the design of Environmental, Social and Gender guidelines—and developing a robust pipeline of climate finance projects. Proposed project ideas include financing solar energy and energy efficiency upgrades for households and micro-businesses in vulnerable communities, as well as infrastructure for electric vehicles and energy storage. The implementation will be managed by a dedicated Project Implementation Unit (PIU) within the R2E2 Fund and overseen by a Project Steering Committee chaired by the Deputy Minister of Environment of Armenia.
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Document type: Report
Annex XXVII: Framework for the GCF project-specific assessment approach
The GCF's project-specific assessment approach (PSAA) allows non-accredited entities to receive funding for a single project by demonstrating the capacity to meet GCF fiduciary, environmental, social, and gender standards for that specific activity. Unlike institutional accreditation, which focuses on organization-wide systems, the PSAA evaluates the entity's ability to deliver a targeted proposal, specifically those in category C/intermediation 3 or category B/intermediation 2. The process involves a two-stage review: an institutional capacity assessment (including project track record checks) and the finalization of legal arrangements. Entities assessed with 'high capacity' are recommended for funding, while those with 'medium capacity' require mitigating factors, and 'low capacity' entities are not recommended. Approved entities are deemed accredited only for the specific project and must report annually on how their broader portfolio is evolving toward low-emission and climate-resilient development.
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Document type: Guide
Actions towards accessing different GCF funding modalities in Peru
The proposal outlines a 12-month program to expand Peru's access to Green Climate Fund (GCF) financing by supporting the accreditation of the state-owned development bank COFIDE and enhancing the fiduciary functions of the existing accredited entity, Profonanpe. Key activities include addressing COFIDE's gaps in environmental and social safeguards (ESS) and gender mainstreaming, and preparing Profonanpe for new on-lending and blending functions. The total requested budget is USD 832,058, with Profonanpe serving as the implementing institution and delivery partner.
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Document type: Report
Consideration of accreditation proposals
The document details the progress of the GCF accreditation process, reporting that 88 entities have been decided for accreditation, with 52 having fully completed the process via effective Accreditation Master Agreements (AMAs). It outlines the pipeline of 112 submitted applications and the support provided to direct access entities, including USD 11.68 million committed through 61 grants. The report specifically recommends the accreditation of seven new applicants (APL090 to APL096) with varying fiduciary and environmental and social (E&S) risk categories, most of whom are subject to specific conditions to close institutional gaps. Additionally, it tracks the status of existing accredited entities in addressing their accreditation conditions and proposes extending the prioritization of entities to the end of the twenty-fifth Board meeting.
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Document type: Report