# Green Finance Readiness (GFR) Assessment Matrix
Methodology v1.0 — English translation

30 criteria across six readiness pillars. Each criterion is scored from 0 to 5 and mapped to 0, 20, 40, 60, 80 or 100. A pillar score is the arithmetic mean of its five criteria. The overall score is the weighted mean of the six pillar scores.

Pillar weights:
1. Governance and Strategy: 20%
2. Green Assets and Project Portfolio: 20%
3. Reporting and Disclosure: 15%
4. Data Quality and Measurement: 15%
5. Green Finance Framework Readiness: 20%
6. Climate Risk Management: 10%

Readiness bands:
A: 85–100, Issuance-ready
B: 70–below 85, Substantially ready
C: 55–below 70, Developing readiness
D: 40–below 55, Early-stage readiness
E: below 40, Not yet ready

If any pillar scores below 40, the rating is lowered by one band (with E as the floor) and marked Conditional. This adjustment is applied once, regardless of the number of weak pillars.

The assessment is based on self-reported practices. It is not independent assurance, a credit rating, an SPO, taxonomy certification or financing approval. The English translation uses the same criterion IDs, response values and calculation as the Turkish version. References to TSRS, CMB guidelines and Türkiye regulations retain their original jurisdictional scope.

## 1. Governance and Strategy

### 1.1 Board oversight
Senior-level accountability for sustainability and climate-related matters.
0. No relevant practices, documentation or awareness are in place.
1. The topic is discussed occasionally, with no formal accountability
2. An executive has been assigned responsibility, but authority and resources are limited
3. A sustainability committee or defined board-level accountability is in place
4. The committee meets regularly, reports to the board and tracks decisions
5. Climate oversight is fully embedded in board governance; competencies are documented and performance is monitored

### 1.2 Emissions reduction targets
The existence and quality of quantified, time-bound emissions reduction targets.
0. No relevant practices, documentation or awareness are in place.
1. A general commitment exists, without quantified targets
2. A quantified target exists, but the base year or reporting boundary is unclear
3. Base-year, time-bound targets have been set for Scope 1 and 2 emissions
4. Interim targets, including Scope 3, have been set (e.g. 2030) and progress is disclosed
5. Targets are science-based (SBTi-validated or equivalent), with a published net-zero roadmap

### 1.3 Integration of climate strategy into business planning
How climate targets inform capital expenditure and budgeting decisions.
0. No relevant practices, documentation or awareness are in place.
1. The strategy document is not connected to the business plan
2. Environmental criteria inform some investment decisions
3. A dedicated green investment line is included in the annual capital expenditure plan
4. The capital expenditure plan is aligned with emissions targets and monitored
5. Capital allocation is stress-tested against climate scenarios; climate is central to corporate strategy

### 1.4 Incentives and performance alignment
Sustainability KPIs in executive remuneration.
0. No relevant practices, documentation or awareness are in place.
1. No link to remuneration exists
2. Sustainability is considered informally in performance reviews
3. A defined ESG KPI is included in senior executive variable remuneration
4. KPIs are quantified, their weightings are disclosed and performance is reported
5. Climate targets are a material component of remuneration, publicly disclosed and auditable

### 1.5 Policies and internal procedures
Environmental policies, supplier codes of conduct and internal procedures.
0. No relevant practices, documentation or awareness are in place.
1. No written policy exists, or it is very general
2. A basic environmental policy has been published
3. Policies are linked to operational procedures
4. Policies cover the supply chain and compliance is monitored
5. Policies are reviewed regularly, breaches trigger corrective measures and supplier audits are conducted

## 2. Green Assets and Project Portfolio

### 2.1 Pipeline of eligible projects
Identifiable investments that can be financed through green finance instruments.
0. No relevant practices, documentation or awareness are in place.
1. Potentially green investments exist but have not been defined
2. Potential projects have been listed, without an eligibility assessment
3. A project list has been mapped against international criteria, including ICMA project categories
4. The eligible project portfolio is documented with investment amounts, timelines and technical specifications
5. The eligible portfolio exceeds the planned issuance amount; financing and refinancing are clearly distinguished

### 2.2 Taxonomy alignment assessment
Assessment of activities against the EU Taxonomy substantial contribution criteria.
0. No relevant practices, documentation or awareness are in place.
1. The taxonomy concept is understood, but no assessment has been conducted
2. A preliminary high-level mapping has been completed
3. Technical screening criteria have been reviewed for core activities
4. The turnover and capital expenditure shares of eligible activities have been calculated
5. A full alignment assessment is supported by independent review; CBAM and Türkiye taxonomy developments are monitored

### 2.3 DNSH and minimum safeguards
Assessment of Do No Significant Harm (DNSH) and minimum social safeguards.
0. No relevant practices, documentation or awareness are in place.
1. The concepts are not understood
2. Environmental impact assessment procedures exist but have not been mapped to DNSH criteria
3. A preliminary DNSH assessment has been completed for priority projects
4. Systematic DNSH screening is applied to all candidate projects
5. DNSH and minimum safeguards, including labour, human rights and anti-bribery controls, are documented and verifiable

### 2.4 Project pipeline and green capital expenditure plan
Visibility over green investments for the next three to five years.
0. No relevant practices, documentation or awareness are in place.
1. No forward-looking plan exists
2. Green investment items can be identified within the general investment plan
3. A three-year green capital expenditure plan is defined with investment amounts
4. The plan is linked to emissions targets and updated annually
5. The multi-year project pipeline is aligned with the financing strategy and issuance timetable

### 2.5 Environmental impact measurement capacity
The ability to quantify the environmental benefits of projects.
0. No relevant practices, documentation or awareness are in place.
1. Environmental impact cannot be estimated
2. Broad qualitative descriptions of benefits exist
3. Indicators such as tCO₂e, MWh and m³ have been calculated for key projects
4. The impact calculation methodology is documented and assumptions are transparent
5. Impact estimates have been independently reviewed; actual outcomes can be verified retrospectively

## 3. Reporting and Disclosure

### 3.1 Alignment with TSRS
Readiness for, or compliance with, disclosure requirements under TSRS 1 and TSRS 2 (Türkiye Sustainability Reporting Standards).
0. No relevant practices, documentation or awareness are in place.
1. TSRS requirements have not been reviewed
2. A gap analysis has been completed
3. An initial TSRS report has been prepared, with material gaps
4. TSRS reporting is comprehensive and aligned with the financial reporting timetable
5. TSRS disclosures have undergone assurance and represent leading practice within the sector

### 3.2 International reporting frameworks
Alignment with voluntary frameworks such as GRI, CDP and integrated reporting.
0. No relevant practices, documentation or awareness are in place.
1. No reporting framework is used
2. A report is partially aligned with one framework
3. Sustainability reports aligned with GRI are published regularly
4. Multiple frameworks, such as GRI reporting and CDP disclosure, are used consistently
5. Integrated thinking is embedded; the CDP score is in the Management band or above

### 3.3 Institutionalised reporting processes
Reporting that is supported by established systems rather than individual effort.
0. No relevant practices, documentation or awareness are in place.
1. Reporting depends on a single individual or external adviser
2. Responsibilities have been assigned, but the process is not documented
3. The reporting calendar, data owners and approval workflow are defined
4. Internal controls are in place, with traceability from source data to published disclosures
5. The process is auditable, consistent year on year and resilient to staff changes

### 3.4 Allocation and impact reporting capacity
Capability to produce the required post-issuance reports.
0. No relevant practices, documentation or awareness are in place.
1. This type of reporting is not understood
2. Requirements have been reviewed, but reporting infrastructure is absent
3. Draft templates or processes are in place for tracking allocation of proceeds
4. The data and processes needed for allocation and impact reporting have been tested
5. A sample report has been prepared in a format suitable for external verification

### 3.5 Public disclosure and accessibility
Presenting information in a format that is readily accessible to investors.
0. No relevant practices, documentation or awareness are in place.
1. Sustainability information is not publicly available
2. Basic information is available on the website but is not up to date
3. Reports are published regularly on the website
4. English-language versions are available and integrated with investor relations
5. Disclosures are data-driven, with ESG data tables and downloadable datasets, supported by active investor engagement

## 4. Data Quality and Measurement

### 4.1 Scope 1 and 2 emissions inventory

0. No relevant practices, documentation or awareness are in place.
1. No inventory exists
2. Calculations are limited to rough estimates
3. A Scope 1 and 2 inventory is calculated in accordance with the GHG Protocol
4. The inventory is prepared annually at facility level using a consistent methodology
5. The inventory is independently verified, with a consistent time series exceeding three years

### 4.2 Scope 3 emissions inventory

0. No relevant practices, documentation or awareness are in place.
1. Scope 3 emissions are not calculated
2. Material categories have been identified through screening
3. The two or three most material categories are calculated
4. All material categories are calculated using supplier data
5. The Scope 3 inventory is verified and linked to emissions reduction targets

### 4.3 Independent verification and assurance

0. No relevant practices, documentation or awareness are in place.
1. No data has undergone external verification
2. Verification is planned
3. Limited assurance has been obtained over emissions data
4. The assurance scope has been extended to water, waste and social data
5. Reasonable assurance has been achieved, or a roadmap towards it is being implemented

### 4.4 Data collection systems

0. No relevant practices, documentation or awareness are in place.
1. Data is fragmented and collected through email or spreadsheets
2. Standardised templates are used
3. A centralised data collection process and accountable data owners are defined
4. Software-enabled data collection includes automated controls
5. Data flows automatically from source systems, such as ERP, meters and SCADA, with minimal manual intervention

### 4.5 KPI monitoring and internal reporting

0. No relevant practices, documentation or awareness are in place.
1. Indicators are compiled only for the annual report
2. A small number of indicators are monitored periodically
3. A defined KPI set is monitored quarterly and reported to management
4. KPIs are tracked against targets and corrective action is taken for deviations
5. Near-real-time monitoring is in place and KPIs inform operational decisions

## 5. Green Finance Framework Readiness

### 5.1 Green Finance Framework
A framework aligned with the ICMA Green Bond Principles and the Capital Markets Board of Türkiye green debt instrument guidelines.
0. No relevant practices, documentation or awareness are in place.
1. No framework document exists
2. Drafting has begun
3. An internally approved draft covers the four core components of the ICMA principles
4. The framework is complete and alignment with CMB guidelines has been checked
5. The framework is published and supported by a Second Party Opinion (SPO)

### 5.2 Use of proceeds and eligibility criteria

0. No relevant practices, documentation or awareness are in place.
1. No definition exists
2. Broad eligible project categories have been listed
3. Categories reference ICMA or taxonomy criteria and include inclusion and exclusion criteria
4. Criteria include quantitative thresholds, such as emissions intensity limits
5. Criteria are aligned with science-based thresholds, including Climate Bonds Initiative sector criteria

### 5.3 Process for project evaluation and selection

0. No relevant practices, documentation or awareness are in place.
1. The process is not defined
2. The decision-maker for project selection has been identified
3. The evaluation committee and decision criteria are documented
4. The process has been tested in practice and decisions have been recorded
5. The process includes environmental and social risk screening, with an auditable decision trail

### 5.4 Management of proceeds and tracking

0. No relevant practices, documentation or awareness are in place.
1. No mechanism exists
2. An approach has been selected, such as a segregated account or virtual portfolio
3. The tracking methodology is documented and the accounting team has been briefed
4. An allocation tracking system is in place and a policy for unallocated proceeds is defined
5. The mechanism is covered by internal audit and ready for external verification

### 5.5 Second Party Opinion readiness

0. No relevant practices, documentation or awareness are in place.
1. The SPO process is not understood
2. Potential providers have been researched
3. SPO documentation requirements have been mapped and gaps identified
4. Documentation is complete and a preliminary discussion with a provider has taken place
5. An SPO has been obtained, or the documentation is sufficiently mature for external review

## 6. Climate Risk Management

### 6.1 Transition risk assessment
Exposure to carbon pricing, CBAM, the Türkiye ETS and regulatory change.
0. No relevant practices, documentation or awareness are in place.
1. No assessment has been conducted
2. Exposure is understood qualitatively, for example through awareness of CBAM impacts
3. CBAM and ETS exposure has been quantified by product and market
4. Financial impacts have been incorporated into financial projections
5. Transition risk is embedded in pricing, investment and market strategy

### 6.2 Physical climate risk assessment
Flooding, drought, heat and supply chain disruption.
0. No relevant practices, documentation or awareness are in place.
1. No assessment has been conducted
2. General awareness exists
3. Facility-level physical climate risk screening has been conducted
4. Risks have been prioritised and impact assessments cover critical facilities
5. Physical climate risks are embedded in insurance, investment and business continuity planning

### 6.3 Climate scenario analysis

0. No relevant practices, documentation or awareness are in place.
1. No analysis has been conducted
2. A conceptual review has been undertaken
3. Qualitative analysis has been conducted for at least one scenario, such as a 1.5°C pathway or current policies
4. Quantitative analysis covers multiple scenarios, using NGFS scenarios or an equivalent approach
5. Scenario findings routinely inform strategy and TSRS disclosures

### 6.4 Integration into enterprise risk management

0. No relevant practices, documentation or awareness are in place.
1. Climate is absent from the risk register
2. Climate has been added to the risk register but has not been assessed
3. Climate risks are assessed using a likelihood-impact matrix
4. Risk owners are assigned and mitigation actions are monitored
5. Climate risks are fully embedded in the enterprise risk management cycle and reported to the board

### 6.5 Climate adaptation and resilience plans

0. No relevant practices, documentation or awareness are in place.
1. No plan exists
2. The need for adaptation has been acknowledged
3. Adaptation actions are defined for priority risks
4. Actions are budgeted and scheduled
5. Adaptation investments are being implemented and their effectiveness is measured