EU SURE Social Bond Framework Second-Party Opinion
Sustainalytics is of the opinion that the EU SURE Social Bond Framework is aligned with the four core components of the Social Bond Principles 2020 with one notable limitation. This assessment is based on the following:
USE OF PROCEEDS
Eligible Social Expenditures under the Framework will help to finance measures by EU Member States to alleviate negative impacts on employment income as a result of the Covid-19 pandemic. This is aligned with categories recognized by the Social Bond Principles. Sustainalytics considers this will create substantial positive social impacts and advance the UN Sustainable Development Goals, specifically SDG 3 and 8. Sustainalytics notes, however, that the SURE Regulation and the Framework do not exclude employment support in sectors considered to have negative environmental and social impacts, and Sustainalytics considers this to be a limitation of the Framework.
The EC’s SURE programme provides funding to Members States under the agreement that they will allocate it to the State’s national short-time employment schemes. The EC has a thorough process to evaluate Member States’ schemes and determine their eligibility for the SURE Programme. Once deemed eligible, upon receipt of funds, Member States may disburse funds according to their schemes’ criteria. This process is aligned with market practice.
MANAGEMENT OF PROCEEDS
Upon receipt of proceeds, Member States shall open an account with the national bank for the management of proceeds. The EC is responsible for ensuring that SURE proceeds are used by the beneficiary Member States exclusively for the Eligible Social Expenditures outlined by the SURE programme regulation. Using a formal internal process, the EC will track and monitor the use of SURE proceeds by Member States. This is aligned with market practice.
European Commission intends to report allocation proceeds on its website, on an annual basis, until full allocation, by the breakdown of SURE proceeds to beneficiary Member States and the main type of Eligible Social Expenditure. Member States will be requested to provide impact and allocation data. Sustainalytics notes that the Commission intends to report on impact, however its ability to do so will be subject to the quality and granularity of data provided by beneficiary Member States. This process is aligned with market practice.