Huntington Bancshares Incorporated : California Voluntary Carbon Market Disclosures

California's Voluntary Carbon Market Disclosures

Business Regula�on Act (AB 1305) ("VCMDA") Disclosure

A business en�ty that operates within California and makes claims as described in Sec�on 44475.2 of the VCMDA is required to disclose on its website informa�on regarding those claims.1 Because it is possible that the VCMDA may be construed to apply to Hun�ngton Bancshares Incorporated ("Hun�ngton"), Hun�ngton is making the disclosure required by Sec�on 44475.2 of the VCMDA.

Since 2017, Hun�ngton has published goals related to the reduc�on of its Scope 1 and Scope 2 carbon emissions. The table below iden�fies the requirements of California's laws and details regarding Hun�ngton's carbon dioxide and greenhouse gas emissions reduc�ons prac�ces. The disclosures below apply to Hun�ngton and its subsidiaries.

AB 1305 Disclosure Requirements	Hun�ngton Disclosure
44475.2(a): All informa�on documen�ng	Hun�ngton engages Energent Solu�ons
how, if at all, a "carbon neutral," "net zero	("Energent"), an independent third-party
emission," or other similar claim was	engineering firm, to perform verifica�on on
determined to be accurate or actually	its emissions data. Energent is a Professional
accomplished, and how interim progress	Engineer registered in the state of Ohio and a
toward that goal is being measured. This	Cer�fied Energy Manager licensed through
informa�on may include, but not be limited	the Associa�on of Energy Engineers.
to, disclosure of independent third-party	Energent verifies that Hun�ngton's emissions
verifica�on of all of the en�ty's greenhouse	repor�ng complies with ISO 14064-3:
gas emissions, iden�fica�on of the en�ty's	Greenhouse gases-Part 3 standards.
science-based targets for its emissions	Energent also verifies that Hun�ngton's
reduc�on pathway, and disclosure of the	emissions repor�ng complies with the GHG
relevant sector methodology and third-party	Protocol Scope 2 Guidance, 2015.
verifica�on used for the en�ty's science-
based targets and emissions reduc�on	Energent verifies the following informa�on
pathway.	regarding carbon emissions on which
	Hun�ngton makes a reduc�on claim:
	• Energy use informa�on for all fuel
	sources that comprise the Scope 1
	and Scope 2 emission categories.
	Scope 1 emissions include the use of
	natural gas and fuel oil as well as fuel
	for our owned corporate fleet and
	owned corporate jet. Scope 2
	emissions include indirect emissions
	associated with the purchase of

1 It should be noted that the VCMDA does define the concepts of "opera�ng within" or "making claims within".

electricity, steam, and chilled water for our facili�es.

• The conversion of energy use informa�on from relevant usage measurements, as applicable, into metric tons of carbon dioxide equivalent (commonly expressed using the abbrevia�on MT CO2e).

Verified energy use informa�on comes directly from Hun�ngton facili�es, owned fleet vehicles, and the owned corporate jet. For facility energy use, Energent relies on actual u�lity bills provided by Hun�ngton's u�lity bill pay third provider to sample consump�on thresholds in accordance with the verifica�on standards. Fuel data from Hun�ngton's owned fleet vehicles and owned corporate jet is provided by the associated vendors. Hun�ngton may publish market- or loca�on-based emissions calcula�ons, and Energent verifies both approaches. Hun�ngton can then measure year-over-year reduc�ons in Scope 1 and Scope 2 emissions from published baselines, which form the basis of its public performance goals.

Hun�ngton publishes actual emissions in MT C02e as well as performance goals compared to published baselines. Hun�ngton compares current year performance against the established emissions baseline to evaluate interim performance. Current year and baseline emissions data would be validated by Energent.

Performance goals are calculated directly from Energent-verified emissions data. As a result, Hun�ngton calculates its Scope 1 and Scope 2 performance goals, usually expressed as a percentage increase or decrease in emissions from an established baseline, without reliance on Energent. Performance goals may be interim, long-term, or ad hoc.

	Hun�ngton may publish ad-hoc performance
	goals to account for significant events, such
	as a merger or acquisi�on.
	Hun�ngton's Scope 1 and Scope 2 emissions
	are not validated as being "science-based" by
	a third party.
	Hun�ngton's current carbon reduc�on goals,
	its progress against current goals, its most
	recent ESG and TCFD Reports, and its most
	recent third-party verifica�on report can be
	found here.
44475.2(b): Whether there is independent	Hun�ngton engages Energent, an
third-party verifica�on of the company data	independent third-party engineering firm, to
and claims listed.	perform verifica�on on its emissions data.
	Energent is a Professional Engineer registered
	in the state of Ohio and a Cer�fied Energy
	Manager licensed through the Associa�on of
	Energy Engineers. Energent verifies that
	Hun�ngton's emissions repor�ng complies
	with ISO 14064-3: Greenhouse gases-Part 3
	standards. Energent also verifies that
	Hun�ngton's emissions repor�ng complies
	with the GHG Protocol Scope 2 Guidance,
	2015.