Cullinan Oncology, Inc. (CGEM): PESTLE Analysis [Nov-2025 Updated]

You're not just investing in Cullinan Oncology; you're betting on the razor's edge of oncology biotech, where the difference between a stock drop of 50% or more and a valuation jump of 100% overnight hinges on a single clinical trial readout. The truth is, Cullinan Oncology's 2025 trajectory is defintely defined by external forces-from increased FDA scrutiny on accelerated approvals to the constant reliance on dilutive equity financing. As a seasoned analyst, I map these critical macro-environmental risks and opportunities-Political, Economic, Sociological, Technological, Legal, and Environmental-because understanding these PESTLE factors is the only way to anticipate where the next major catalyst or headwind is coming from, allowing you to make an informed strategic move.

Cullinan Oncology, Inc. (CGEM) - PESTLE Analysis: Political factors

Increased FDA scrutiny on accelerated approval pathways

You need to be acutely aware that the regulatory landscape for accelerated approval is tightening, which directly impacts Cullinan Oncology's lead asset, zipalertinib, and its entire oncology pipeline. The Food and Drug Administration (FDA) is under pressure to ensure confirmatory trials are completed diligently and quickly after an accelerated approval is granted. This is not a minor headwind; oncology products represented 83% of accelerated approvals between 2012 and 2021, putting Cullinan Oncology squarely in the crosshairs.

In January 2025, the FDA issued new draft guidance clarifying its expectations, particularly emphasizing the importance of timely confirmatory trials to verify clinical benefit. For Cullinan Oncology, which initiated a rolling New Drug Application (NDA) submission for zipalertinib for non-small cell lung cancer (NSCLC) with EGFR exon 20 insertion mutations in Q4 2025, this means the Phase 3 REZILIENT3 confirmatory study must be demonstrably 'underway.' If the confirmatory trial fails to show clinical benefit or is not conducted diligently, the FDA can now act more swiftly to withdraw approval. That's the one-liner: the clock on post-market trials starts ticking a lot faster now.

Here's a quick look at the direct implications for Cullinan Oncology's key asset:

• Zipalertinib NDA: Rolling submission for accelerated approval initiated in Q4 2025.
• Confirmatory Trial: Phase 3 REZILIENT3 is underway, which is critical for maintaining accelerated approval status.
• Risk: Heightened regulatory scrutiny could mean longer review times or more stringent post-marketing requirements than previously anticipated.

US government focus on drug price negotiation (Inflation Reduction Act)

The Inflation Reduction Act (IRA) of 2022 fundamentally shifts the financial model for biopharma, even for pre-revenue companies like Cullinan Oncology. While the first negotiated prices take effect in 2026, the law's structure is already changing R&D investment decisions today. The core issue for Cullinan Oncology is that zipalertinib is a small-molecule drug, which is subject to Medicare price negotiation after only 9 years of market exclusivity, compared to 13 years for biologics.

This four-year difference in market exclusivity is massive for a drug's net present value (NPV). Modeling suggests the Drug Price Negotiation Program (DPNP) could reduce the discounted value of small-molecule projects by a range of 22% to 95%. For a company with a Q3 2025 net loss of $50.6 million, future revenue predictability is defintely a major concern.

The silver lining is the 'Small Biotech Exception' for 2026 through 2028, which shields certain drugs from negotiation if the manufacturer's total Part D expenditures meet specific low-threshold criteria. As a company with no marketed products, Cullinan Oncology is likely protected in the near-term negotiation cycles, but the long-term shadow of price controls remains a strategic risk for zipalertinib's commercial life after 2035.

Geopolitical risk impacting global clinical trial site access

Geopolitical instability, from regional conflicts to US-China strategic competition, is a persistent operational risk in 2025 that affects global clinical trial execution. For a biotech like Cullinan Oncology, which is running global clinical development for key programs like CLN-978 (a T cell engager for autoimmune diseases), relying on international sites introduces logistical and regulatory complexity.

The main risk here is the operational drag: monitors are less able to visit sites, and sites in unstable regions struggle with staff fatigue and supply chain uncertainty. Plus, the FDA is increasing scrutiny on trials that rely solely on foreign recruitment. This pushes companies to diversify their trial footprint, often increasing costs and complexity. Cullinan Oncology must ensure its global network of clinical investigators, especially for CLN-978, is resilient and compliant with the heightened FDA focus on US-based enrollment.

Potential for enhanced R&D tax credits or government funding

On a positive note, the US government continues to offer significant incentives for domestic R&D, which directly benefits Cullinan Oncology's substantial research spend. For Q3 2025 alone, Cullinan Oncology reported R&D expenses of $42.0 million. The permanent federal R&D tax credit is a dollar-for-dollar reduction against taxes owed, typically worth 7% to 10% of Qualified Research Expenses (QREs) for biotech companies.

More importantly, there is active legislative effort to restore the immediate expensing of domestic R&D costs. Under current law, these costs must be amortized over five years, which negatively impacts liquidity. The proposed American Innovation and R&D Competitiveness Act of 2025 aims to restore immediate expensing, which would be a major cash-flow boost for R&D-heavy companies. For an early-stage company, this non-dilutive funding is critical for extending the cash runway, which is currently projected into 2029 with $475.5 million in cash and investments as of September 30, 2025.

Cullinan Oncology, Inc. (CGEM) - PESTLE Analysis: Economic factors

The economic landscape for Cullinan Oncology is defined by a high-cost, high-reward model typical of a clinical-stage biopharmaceutical company. The core economic factors center on managing a significant capital burn rate, mitigating the risk of shareholder dilution, and realizing the substantial revenue potential locked within key pipeline partnerships, all while navigating a persistent global inflationary environment.

High capital burn rate due to clinical trial costs

Cullinan Oncology's primary economic challenge is its substantial cash burn, driven by the escalating costs of running multiple global clinical trials across its oncology and immunology pipeline. This is clearly visible in the 2025 quarterly financial reports, which show a sharp increase in Research and Development (R&D) expenses.

For the second quarter of 2025, R&D expenses surged to $61.0 million, a significant jump from $36.3 million in the same period of 2024, directly reflecting higher clinical trial costs. Consequently, the net loss for Q2 2025 widened to $70.1 million, compared to $42.0 million in Q2 2024. The trend continued into Q3 2025, with R&D expenses at $42.0 million and a net loss of $50.6 million. Here's the quick math on the near-term burn:

This kind of spending is a necessary cost of doing business in biotech; it signals aggressive advancement of the pipeline. The trailing twelve months (TTM) cash burn as of June 2025 was approximately $172 million, an increase of 35% over the prior year. That's defintely a lot of money to spend on drug development.

Reliance on equity financing and dilutive fundraising

As a pre-revenue company, Cullinan Oncology relies heavily on its cash reserves and the potential for future equity financing (selling shares) to fund operations. The good news is the company is in a strong financial position, reporting cash, cash equivalents, and investments of $475.5 million as of September 30, 2025. This substantial balance is projected to provide a cash runway that extends into 2029, which is a long horizon for a biotech.

Still, the high burn rate means future fundraising is an inherent risk. The TTM cash burn of $172 million represents about 45% of the company's market capitalization of approximately $381 million (as of October 2025). This ratio highlights the potential for significant shareholder dilution if the company needs to raise capital before a major product approval or partnership milestone is achieved. The market is constantly watching this.

Partnership revenue potential from key pipeline assets (e.g., CLN-081)

The most significant near-term economic opportunity lies in the partnership with Taiho Oncology for zipalertinib (development code: CLN-081). This collaboration is structured as a co-development and co-commercialization agreement, where Cullinan Oncology and Taiho Oncology share equally in the development expenses and future potential U.S. profits and losses. The key catalyst for a shift to profit-sharing is the regulatory submission and approval.

Key economic milestones for the partnership include:

• NDA Submission: Taiho plans to submit a New Drug Application (NDA) for zipalertinib in relapsed/refractory EGFR ex20ins NSCLC in the second half of 2025, with the rolling submission completion anticipated in the first quarter of 2026.
• Profit-Sharing: Upon U.S. approval, the 50/50 profit and loss sharing arrangement will commence, providing Cullinan its first meaningful commercial revenue stream.

Additionally, the in-licensing of the BCMAxCD3 bispecific T cell engager, velinotamig, from Genrix Bio creates a long-term revenue opportunity. Genrix Bio is eligible to receive up to $292 million in development and regulatory milestones, plus up to an additional $400 million in sales-based milestones, and tiered royalties on net sales outside of Greater China. This is a massive potential payout, but it also signals a powerful, high-value asset in the pipeline.

Global inflation impacting supply chain and operational expenses

Like all biopharma firms, Cullinan Oncology is exposed to the persistent effects of global inflation and supply chain volatility. While the company does not provide specific inflation-related cost increases, the sector is facing significant headwinds in 2025.

The general economic reality is that global supply chain costs are projected to rise up to 7% above inflation by the fourth quarter of 2025. For a company running complex clinical trials, this translates to higher costs for:

• Active Pharmaceutical Ingredients (APIs): New U.S. trade tariffs, including a potential 25% duty on APIs from China, are pressuring costs for drug manufacturing.
• Clinical Trial Operations: Increased costs for contract research organizations (CROs), specialized labor, and global logistics.
• G&A Expenses: General and administrative costs are also rising, hitting $13.6 million in Q3 2025, up from $13.3 million in Q3 2024.

What this estimate hides is the potential for clinical trial delays due to supply chain disruption, which can be far more costly than the direct inflationary pressure itself. The economic factor here is not just the price of goods, but the risk to the timeline of the company's value-driving catalysts.

Cullinan Oncology, Inc. (CGEM) - PESTLE Analysis: Social factors

Growing patient advocacy for novel cancer treatments

Patient advocacy groups are no longer just support networks; they are powerful, sophisticated drivers of policy and clinical adoption, which directly impacts Cullinan Oncology, Inc.'s market potential. These groups are pushing hard to dismantle barriers like insurance hurdles and complex logistics, demanding faster access to innovative treatments like targeted therapies and Antibody-Drug Conjugates (ADCs).

The core of this advocacy is a demand for equitable, high-quality care. For a company like Cullinan Oncology, Inc., which is focused on a niche like the EGFR exon 20 insertion (ex20ins) mutation in Non-Small Cell Lung Cancer (NSCLC), strong patient support can accelerate regulatory discussions and drive faster clinical uptake. This is defintely a tailwind for novel drug developers.

• Advocacy focuses on removing financial and logistical barriers.
• Decentralized care models are expanding trial access beyond major academic centers.
• Policy efforts push for reforms prioritizing access and affordability.

Increasing global prevalence of target cancer types (e.g., NSCLC)

The sheer scale of the lung cancer burden creates a massive, persistent market need for Cullinan Oncology, Inc.'s lead candidate, Zipalertinib. Lung cancer remains the deadliest cancer globally, contributing to 18.7% of all cancer-related fatalities. The overall global lung cancer treatment market is valued at approximately $20.01 billion in 2025, reflecting the enormous economic and health impact.

Non-Small Cell Lung Cancer (NSCLC) accounts for about 85% of all lung cancer cases worldwide. While Cullinan Oncology, Inc.'s Zipalertinib targets a specific, smaller subset-the EGFR ex20ins mutation-this still represents a significant patient population, as this mutation accounts for up to 4% of all NSCLC cases globally. That's a niche, but a large one, and it's a critical unmet need for patients who have few other options.

Here's the quick math on the oncology market landscape:

Public perception of drug affordability and access

This is the biggest near-term risk for the entire biotech sector, and Cullinan Oncology, Inc. is not immune. The public perception of high drug prices is driving significant policy action in the US. Consider the context: in 2023, the launch price for 95% of new anticancer therapies exceeded $100,000 per year. This cost pressure is real, and it's forcing patients to make terrible choices; one-third of the public reports skipping doses due to cost.

Total US spending on anticancer therapies (excluding supportive care) is projected to climb from $99 billion in 2023 to an estimated $180 billion by 2028. This unsustainable trajectory means that even highly effective novel drugs like Zipalertinib will face intense scrutiny from payers, politicians, and the public on their value proposition. Cullinan Oncology, Inc. must clearly articulate the clinical and economic value of targeting a specific, difficult-to-treat mutation to justify its price.

Shifting patient demand toward targeted and personalized therapies

The social shift toward personalized medicine is a major opportunity for Cullinan Oncology, Inc. Patients and clinicians are increasingly demanding therapies that match a tumor's unique genetic profile, moving away from broad-spectrum chemotherapy. This is why the targeted therapies segment held the largest market share in the cancer drug manufacturing market in 2024.

The market for next-generation cancer therapeutics, which includes targeted agents, is valued at $92.54 billion in 2025. This demand fuels the rapidly growing oncology biomarker market, which is essential for identifying the right patients for drugs like Zipalertinib; that market is valued at $38.62 billion in 2025. Cullinan Oncology, Inc.'s focus on the EGFR ex20ins mutation is perfectly aligned with this trend of precision oncology.

What this estimate hides is the challenge of timely biomarker testing, which is often a bottleneck in getting patients onto the right targeted therapy quickly. Cullinan Oncology, Inc. needs to ensure diagnostic access is as smooth as the drug's eventual launch.

Cullinan Oncology, Inc. (CGEM) - PESTLE Analysis: Technological factors

Focus on next-generation targeted therapies (e.g., bispecific antibodies)

Cullinan Oncology's core technological strength lies in its focus on next-generation therapies, primarily bispecific T cell engagers (TCEs). These molecules are engineered to simultaneously bind to a target on a cancer or autoimmune cell and a T cell, effectively using the body's own immune system to destroy the diseased cells. This is a significant leap from traditional monoclonal antibodies.

The company has two key bispecific assets in the clinic. CLN-049, a FLT3xCD3 TCE for acute myeloid leukemia (AML), is in a Phase 1 study and has already shown promising results, delivering a composite complete response (CRc) rate of approximately 30% at clinically active doses in a heavily pretreated patient population, a strong signal for a Phase 1 trial. The other, CLN-978 (CD19xCD3 TCE), is being rapidly advanced in autoimmune diseases, with initial safety data expected in the first half of 2026. This dual-focus leverages the same T cell engager technology across both oncology and immunology, a smart, capital-efficient way to use their platform. The recent in-licensing of Velinotamig (BCMAxCD3 TCE) in June 2025 for a $20 million upfront fee further solidifies this technological platform.

Here is a quick view of the leading next-generation programs:

Advancements in biomarker identification for patient stratification

Precision is everything in modern oncology, and Cullinan is using specific biomarkers to stratify (or select) patients for its most advanced programs. The most concrete example is the partnership with Taiho Oncology on Zipalertinib, which is explicitly designed to treat non-small cell lung cancer (NSCLC) patients with the EGFR exon 20 insertion (ex20ins) mutation. This mutation is the patient-selection biomarker, allowing for a highly targeted approach that led to a confirmed objective response rate (ORR) of 35% in pretreated patients.

Conversely, the technology is also proving its value by overcoming a biomarker hurdle. The data for CLN-049 is noteworthy because it demonstrated anti-leukemic activity in AML patients regardless of their FLT3 mutational status. This means the bispecific technology has the potential to treat a broader, 'all-comer' population for a disease where FLT3 status is typically a critical stratification factor, defintely simplifying the treatment paradigm. The company's focus on well-validated targets like CD19 and BCMA in autoimmune disease also represents a strategic, biomarker-driven approach to B-cell depletion.

Use of AI/Machine Learning to optimize clinical trial design

While Cullinan has not publicly detailed an internal, dedicated Artificial Intelligence (AI) or Machine Learning (ML) platform for clinical trial optimization as of late 2025, the industry trend is a massive, unavoidable technological force. For a clinical-stage biotech that reported $42.0 million in Research and Development (R&D) expenses for the third quarter of 2025, maximizing trial efficiency is a must-do. You simply cannot afford the cost and time of inefficient trials when you are burning cash to advance your pipeline.

The near-term opportunity for Cullinan is to adopt AI/ML to:

• Accelerate patient recruitment by using AI to scan electronic health records (EHRs) for the highly specific biomarkers they target, like EGFR ex20ins.
• Optimize trial protocols in real-time based on accumulating patient data, a key benefit of adaptive trial designs enabled by AI.
• Identify predictive biomarkers from multi-omic data, which would be critical for stratifying the patient population for their bispecific TCEs in earlier phases.

The market expects 2025 to be a 'turning point' for AI in precision oncology, so integrating these tools is a strategic imperative to maintain their cash runway, which is currently projected into 2029.

Intellectual property (IP) strength for novel drug candidates

Strong intellectual property (IP) is the bedrock of a biotech's valuation, and Cullinan has secured a crucial piece of protection for its lead wholly-owned asset. The United States Patent and Trademark Office (USPTO) issued a key composition of matter patent for CLN-978, which is expected to extend patent protection until at least 2042. This long-term exclusivity is a significant technological barrier to entry for competitors and a major value driver for the asset, providing nearly two decades of potential market protection from the current date.

The company's strategy of developing proprietary molecules like CLN-978 internally, combined with strategic in-licensing for assets like Velinotamig, helps build a diversified and robust IP portfolio. For a company valued primarily on its pipeline, this patent strength provides the confidence needed to continue investing heavily in R&D, knowing the eventual commercial returns are protected. Protecting that IP globally is the next big challenge.

Cullinan Oncology, Inc. (CGEM) - PESTLE Analysis: Legal factors

Critical need for strong patent protection against generic entry

For a clinical-stage biotech like Cullinan Oncology, intellectual property (IP) is the primary asset, and its legal defense is non-negotiable. The critical need is to maintain exclusivity for their pipeline candidates, especially as they move toward commercialization, which acts as a bulwark against generic or biosimilar competition.

The company recently secured a significant legal foundation for its lead immunology candidate, CLN-978 (a CD19xCD3 bispecific T cell engager). In 2025, Cullinan received a U.S. composition-of-matter patent for CLN-978, which extends protection to at least 2042. This long-term exclusivity is defintely the main value driver for the program, providing a clear path to recoup the substantial R&D investment.

Here's the quick math on IP defense cost: While Cullinan's R&D expenses were already high at $42.0 million for the third quarter of 2025, a single complex patent infringement lawsuit can cost a biopharma company tens of millions of dollars, so a strong patent from the start saves money later.

Strict adherence to global clinical trial regulations (GCP)

Cullinan Oncology's strategy is inherently global, meaning strict adherence to Good Clinical Practice (GCP) and international regulatory standards is a core legal requirement. Failure here means a complete halt to a program, wasting the $475.5 million in cash and investments the company holds as of September 30, 2025.

The company's active pipeline demonstrates this global compliance burden:

• Zipalertinib (Oncology): Partner Taiho initiated a rolling New Drug Application (NDA) submission to the U.S. Food and Drug Administration (FDA) in November 2025, a process requiring exhaustive documentation of the REZILIENT1 trial data under FDA regulations.
• CLN-978 (Immunology): The European Medicines Agency (EMA) approved a Clinical Trial Application (CTA) in April 2025 to initiate a Phase 1 study in rheumatoid arthritis in Germany and Italy in Q2 2025.

Navigating these multi-jurisdictional approvals (FDA, EMA, and others for trials in Australia) requires a massive legal and regulatory infrastructure. You can't afford a single misstep in data integrity.

Risk of intellectual property litigation with competitors

Despite securing a strong patent for CLN-978, the oncology and autoimmune T cell engager space is fiercely competitive, and the risk of intellectual property litigation is a constant overhang. The industry landscape is rife with disputes over compound patents, formulation, and manufacturing processes, especially as a drug nears the market.

The risk is two-fold:

• Defending Zipalertinib: As the partner Taiho moves toward potential U.S. regulatory approval for zipalertinib, this high-value drug becomes a target for competitors seeking to challenge the underlying patents, a common tactic in late-stage drug development.
• Platform Technology Challenges: Cullinan's focus on T cell engagers for both oncology and autoimmune diseases means their core technology platform could face a broader challenge from biotech rivals looking to disrupt their 'modality-agnostic' approach.

Litigation is expensive, with some serial patent cases in the pharma sector dragging on for years and costing hundreds of millions, so Cullinan must budget for potential legal defense.

Evolving data privacy laws (e.g., HIPAA, GDPR) for patient data

The nature of clinical trials means Cullinan Oncology handles vast amounts of highly sensitive patient health information (PHI), subjecting it to stringent global data privacy laws. Compliance is complex because they operate in the U.S., Europe, and Australia.

The two main federal and international frameworks are the U.S. Health Insurance Portability and Accountability Act (HIPAA) and the European Union's General Data Protection Regulation (GDPR). However, the legal environment is fragmenting, adding new layers of complexity.

Cullinan's October 2025 update to its Consumer Health Data Notice shows a proactive response to this evolving legal risk by explicitly addressing new U.S. state laws:

This constant need to update policies for state-level laws, in addition to federal and international rules, increases the General and Administrative (G&A) legal compliance costs, which were already $13.6 million in Q3 2025. Staying compliant is a full-time, global job.

Cullinan Oncology, Inc. (CGEM) - PESTLE Analysis: Environmental factors

You are a clinical-stage biopharmaceutical company, so your environmental risk profile is different from a large-scale manufacturer, but it is defintely not zero. The primary risks for Cullinan Oncology, Inc. are tied to the global footprint of your clinical trials and the investor-driven mandate for Environmental, Social, and Governance (ESG) transparency, which is now a core part of valuation.

Here's the quick math: If a Phase 3 trial fails, the stock price drops by 50% or more. If a drug gets accelerated approval, the valuation can jump 100% overnight. It's that simple.

Next Step: Finance: Track the cash runway against the next major clinical milestone announcement date.

Management of hazardous biowaste from research and manufacturing

As a company focused on developing bispecific T cell engagers like CLN-978 and CLN-049, Cullinan Oncology, Inc. generates biohazardous waste from its preclinical research and clinical-stage manufacturing. This waste-including contaminated lab materials, sharps, and residual drug product-requires strict handling under the U.S. Resource Conservation and Recovery Act (RCRA) and state-specific regulations.

While Cullinan Oncology, Inc. outsources much of its manufacturing, the liability and cost for managing research and development (R&D) waste remain. Your R&D expenses were substantial, totaling $61.0 million in the second quarter of 2025 alone, up from $36.3 million in Q2 2024. A portion of this increase funds the necessary, and rising, compliance costs for waste disposal, which can be 5 to 10 times more expensive than standard solid waste disposal.

The key risk here is operational compliance. A single regulatory violation can lead to fines and, more critically, interrupt the research pipeline, slowing down the development of key assets like CLN-978, which is in global Phase 1 studies for autoimmune diseases.

Focus on sustainable supply chain for drug components

The push for a sustainable supply chain in 2025 is not just about goodwill; it's about business resilience. Disruptions to global supply chains surged by 38% in 2024, and the pharmaceutical industry is now integrating sustainability to mitigate these risks. Cullinan Oncology, Inc.'s supply chain for its drug components-the active pharmaceutical ingredients (APIs) for its small molecule zipalertinib and the complex biologics for its T cell engagers-is a critical vulnerability.

The industry is moving toward green logistics and circular supply chains, and you need to ensure your contract manufacturers and suppliers are aligned. This includes:

• Sourcing materials that meet ethical standards.
• Using eco-friendly packaging for temperature-sensitive cold chain logistics.
• Demanding clear Scope 3 emissions data from all upstream suppliers.

Honesty, if you can't report on your suppliers' emissions, you risk exclusion from key markets or losing major clients who have their own net-zero commitments.

Carbon footprint of global clinical trial logistics and travel

The sheer logistics of running global clinical trials-like the Phase 1 studies for CLN-978 across the United States, Europe, and Australia and the pivotal Phase 3 REZILIENT3 trial for zipalertinib-create a significant carbon footprint. This is a major, often overlooked, environmental factor in the biotech sector.

Industry analysis shows that a single large Phase 3 clinical trial can generate over 3,100 metric tons of CO₂ equivalent gasses (mT CO₂e). Your R&D spending, which includes these trial costs, was $42.0 million in Q3 2025. The emissions break down into a few key areas that Cullinan Oncology, Inc. must address:

The industry is now using carbon calculators to measure this impact, and investors will soon expect you to report on it. You need to start identifying digital solutions to decarbonize clinical research now.

Investor pressure for transparent Environmental, Social, and Governance (ESG) reporting

By 2025, ESG reporting is no longer a fringe issue; it is a baseline requirement for maintaining investor trust. Institutional investors like BlackRock demand structured, transparent, and financially relevant disclosures, moving beyond general sustainability narratives. The ability to quantify and explain ESG risks is essential for a company like Cullinan Oncology, Inc., which relies heavily on investor capital to fund its long runway into 2029.

Your cash and investments stood at a strong $475.5 million as of September 30, 2025. Protecting that capital and attracting future funding means meeting the new ESG standards, which include frameworks like the International Sustainability Standards Board (ISSB). Investors are actively looking for ESG signals that point to business resilience and long-term profitability. If you don't provide credible data on your environmental risks, you risk a higher cost of capital and exclusion from sustainable finance opportunities.