Sustainability information disclosure

SFDR Sustainability-Related Disclosures

SUSTAINABILITY-RELATED DISCLOSURE

Product Name:Activia Properties Inc.

Legal Entity Identifier: 353800RPGYN3ML8CXV54

Activia Properties Inc. ("API”) promotes environmental or social characteristics, but does not have as its objective a sustainable investment within the meaning of Article 9(1) of Regulation (EU) 2019/2088 (“SFDR”). API does not have any employees in accordance with the prohibition on having employees under the Act on Investment Trusts and Investment Corporations of Japan, and API relies on TLC REIT Management Inc. (the “Asset Manager”) to manage and operate the properties in the portfolio. API and the Asset Manager are hereinafter referred to collectively as “we,” “us” or “our”. References to “fiscal year” are to the 12 months began or beginning April 1 of the year, and references to “fiscal period” are to the 6 months began or beginning June 1 or December 1 of the year, unless noted otherwise.

Summary

No sustainable investment objective

The financial products offered by API promote environmental or social characteristics, but do not have as its objective sustainable investment.

Environmental or social characteristics of the financial product

API and the Asset Manager promote Environmental / Social characteristics through a host of environmental, social and governance enhancement initiatives, aligned with the United Nations’ 17 Sustainability Development Goals (“SDGs”). Specifically, we implement various environmental initiatives at our properties including those against climate change, supporting local communities, tenants, employees, and public health.

As a member of the Tokyu Fudosan Holdings Group, which is a leading real estate developer specialized in providing best-in-class retail, office, residential, entertainment, and lifestyle properties and facilities in various countries in a more sustainable way, we all share the same approach to sustainability and work together to promote sustainability in our business practices.

Investment strategy

The Asset Manager has established its Sustainability Policy in April 2019 and shares the Tokyu Fudosan Holdings Group’s Sustainability Vision. A Sustainability Department was also established in 2021 to expand the functionality of the Sustainability Promotion System, which prescribes the organizational structure under which relevant committees, departments, and the board of directors interact to promote sustainability initiatives and programs. The review and assessment of material ESG risks and opportunities are built into our investment decision process.

We ensure the investment strategy is implemented on a continuous basis by incorporating review and assessment of material ESG-related risks and opportunities into our investment decision process. We consider ESG-related due diligence review before investing in properties.

Proportion of investments

We use BELS, CASBEE, DBJ Green Building Certification, and Tokyo Low-Carbon Small and Medium-Sized Model Building for environmental certification in API’s portfolio. We also track and monitor these property-level environmental certifications, to assess the environmental performance of our portfolio.

We consider a property as “green-certified” if it receives one or more stars in the CASBEE ranking system, receives one or more stars in the BELS ranking system, receives one or more stars in the DBJ Green Building Certification ranking system, or receives A1 or a higher level in Tokyo Low-Carbon Small and Medium-Sized Model Building reporting system. We call our property that receives any such certifications “Green-certified Asset”. As of May 31, 2023, approximately 71% of our properties were Green-certified Assets, and approximately 29% of our properties were not Green-certified Assets based on gross floor area. Our target is to continue to maintain the percentage of Green-certified Assets at 70% or more by 2030.

Monitoring of environmental or social characteristics

For the purpose of monitoring and tracking our performance on Environmental /Social characteristics, we mainly use specific indicators to check the attainment every fiscal period or fiscal year, at both the portfolio level and the property level.

The following are our key performance indicators: Overall ESG performance; Climate change initiatives - Environmental certification/Greenhouse gas (“GHG”) emissions/Energy consumption intensity/Water Consumption management/Other ESG data coverage; and Social initiatives - Local community/Tenants.

Methodologies

The Asset Manager’s Sustainability Promotion Council holds quarterly meetings to deliberate and decide upon matters concerning the promotion of ESG such as passing resolutions for basic ESG policies, annual plans for ESG promotion, annual activities planning and reporting, and initiatives for various ESG measures under our portfolio management strategy. We have instituted a number of initiatives, at both the portfolio level and the property level, to promote Environmental /Social characteristics including climate change initiatives, local community initiatives, and tenant and employee initiatives.

Data sources and processing

The Asset Manager obtains the relevant data as provided by the established third-party organizations that issue environmental certifications for the properties in our portfolio. Obtaining the environmental certifications issued by the established third-party organizations helps to ensure the data quality. Also, the Asset Manager obtains an independent assurance statement every year from a third-party organization for the data including energy consumption, GHG emissions and water use, which helps to ensure the data quality.

Limitations to methodologies and data

The primary limitation to the methodology or data source is the necessity of our reliance on the tenants and property management companies for raw data at the property level. In addition, data at the property level provided by the tenants and property managers is generally updated on an annual basis. Accordingly, property-specific data will therefore not always be fully up to date.

However, limitations to the methodology and data are not expected to affect the attainment of the environmental or social characteristics promoted by API in any material way.

Due diligence

Prior to investment in a property, the Asset Manager conducts due diligence on the property that considers various ESG factors such as: (i) use of asbestos-containing building materials; (ii) PCB (polychlorinated biphenyl)-containing machines and wastes existence; (iii) annual energy consumption of any company or business; (iv) annual energy consumption of any property or facility; and (v) potential soil contamination.

Engagement policies

As discussed in detail above, we invest only in properties that have been subjected to ESG-related due diligence review. We may exclude a future potential investment as a result of the ESG-related due diligence review. In addition, we do not invest in real estate assets involved in the extraction, storage, transport, or manufacture of fossil fuels.

Designated reference benchmark

API has no benchmark index designated as a reference benchmark to meet the environmental or social characteristics promoted by API.

No sustainable investment objective

The financial products offered by API promote environmental or social characteristics, but do not have as its objective sustainable investment.

Environmental or social characteristics of the financial product

For the existing retail and office properties in our portfolio, we promote E/S characteristics through a host of environmental, social and governance (“ESG”) enhancement initiatives, aligned with the United Nations’ 17 Sustainability Development Goals (“SDGs”). Specifically, we implement various environmental initiatives at our properties including those against climate change (installation of energy saving equipment such as LED lightings, motion sensors for automatic light extinction, energy-optimizing air conditioners, energy-efficient windows and glasses, environmental-friendly escalators, and indoor plants with deodorizing and temperature control functions; use of natural energy through wind-power generation and top light), in water resources (use of recycled water and installation of water-saving faucets, urinals, and toilets), in recycling of waste and materials (use of recycled materials and equipment in our buildings, such as wood decks from recycled wood, and carpets, wall tiles and chairs made of recycled materials, recycled asphalt on the roads in our building sites, and strawberries grown at a property using restaurant food waste as a fertilizer), and in reducing harmful substances (use of building materials emitting less VOCs and rooftop gardening for absorbing dust).

Our environmental initiatives are aligned with the SDG Target 7.3 (By 2030, double the global rate of improvement in energy efficiency), 12.5 (By 2030, substantially reduce waste generation through prevention, reduction, recycling and reuse) and 12.8 (By 2030, ensure that people everywhere have the relevant information and awareness for sustainable development and lifestyles in harmony with nature). For social characteristics, we aim to coexist with local communities where our properties are located while supporting work environment that encourages diverse work styles and human resource development, promoting the health and well-being of tenants and business partners, enhancing engagement with local communities and our supplies, and contributing to solving social issues. Specifically, our social initiatives include supporting local communities (donating to local communities and collaborating with them on natural disaster and infectious disease prevention and response; sponsoring, collaborating on, and providing meeting spaces for local events), tenants and their employees (amenities such as cafeterias and stores, conducting customer satisfaction surveys, and providing temporary rent reduction to tenants affected by public crises such as the COVID-19 pandemic), employees (supporting work-style reform such as paid leave and remote work, promoting workplace diversity, implementing training programs, and supporting certification acquisition), and business-continuity-planning (having earthquake-resistant building structure and emergency power generators and stockpiling disaster-relief supplies for disaster prevention) and public health measures (installation of hand sanitizers, disinfection of frequently touched areas, anti-virus coating in common areas, and ventilation with fresh-air treatment machines).

Our social initiatives are aligned with the SDG Target 11.3 (By 2030, enhance inclusive and sustainable urbanization and capacity for participatory, integrated and sustainable human settlement planning and management in all countries) and 12.8 (By 2030, ensure that people everywhere have the relevant information and awareness for sustainable development and lifestyles in harmony with nature).

Investment strategy

The Asset Manager, TLC REIT Management Inc., has established its Sustainability Policy in 2019 and shares the Tokyu Fudosan Holdings Group’s Sustainability Vision. The Asset Manager’s President & CEO is the Chief Sustainability Officer as well as the Chairman of the Sustainability Promotion Council that meets regularly. A Sustainability Department was also established in 2021 to expand the functionality of the Sustainability Promotion System, which prescribes the organizations structure under which relevant committees, departments, and the Board of Directors interact to promote sustainability initiatives and programs. The review and assessment of material ESG risks and opportunities are built into our investment decision process.

Investment research and investment decision-making. We conduct preliminary investment research to understand how our activities impact material ESG factors and how these can affect our reputation, capital value and stakeholders. Our investment research analyzes various ESG factors such as how we can reduce our environmental load, coexist with local communities where the property is located, contribute to solving social issues, and achieve sustainable growth for all stakeholders. We consider these ESG factors throughout an asset’s lifecycle by tracking and monitoring the sustainability performance of our assets and collaborating with our workforce, partners and communities. The Asset Manager’s Investment Committee considers due diligence findings on ESG factors along with other economic and operational considerations when making a final decision to invest in a property.

Green bonds. From time to time, we issue investment corporation bonds earmarked for use in certain projects serving as countermeasures against global warming or providing environmental benefits under our green bond framework (collectively, the “green bonds”), which is generally aligned with the Green Bond Principles, a voluntary guideline of International Capital Market Association. Our green bond framework requires the proceeds from our green bonds to be allocated to funds for (i) acquisition of the “Eligible Green Projects” (as defined below) or (ii) refurbishments fulfilling certain “Eligibility Criteria” (as defined below), or (iii) refinancing the existing loans/investment corporation bonds which have been allocated to acquire Eligible Green Projects or refurbishments meeting Eligibility Criteria. Under our green bond framework, the Eligible Green Projects are defined as buildings that have achieved, or are expected to achieve, the top two levels of one or more of the third-party green building certifications/re-certifications under Building Energy-efficiency Labeling System (“BELS”), Comprehensive Assessment System for Built Environment Efficiency (“CASBEE”) or Development Bank of Japan (“DBJ”) Green Building Certification, within 36 months prior to the payment date of such green bonds. Under our green bond framework, the Eligibility Criteria are defined as refurbishments that have been completed, or are expected to be completed, with a primary purpose of achieving (i) more than 10% reduction in CO2 emissions or energy consumption, (ii) more than 10% reduction in water consumption or (iii) new third-party green building certification or improvement in third-party green building certification required under the Eligible Green Projects, within 36 months prior to the payment date of such green bonds. As of May 31, 2023, 19 properties in our portfolio are Eligible Green Projects, and the aggregate principal amount of our green bonds outstanding is ¥19.4 billion.

Proportion of investments

We use BELS, CASBEE, or DBJ Green Building Certification, and Tokyo Low Carbon Small and Medium-Sized Model Building for the environmental certification of the properties in our portfolio. We also track and monitor these property-level environmental certifications to assess the environmental performance of our portfolio. We consider a property as “green-certified” if it receives one or more stars in the CASBEE ranking system, receives one or more stars in the BELS ranking system, receives one or more stars in the DBJ Green Building Certification ranking system or receives A1 or a higher level in Tokyo Low-Carbon Small and Medium-Sized Model Building reporting system. We call our property that receives any such certifications as “Green-certified Asset”. As of May 31, 2023, approximately 71% of our properties were Green-certified Assets, and approximately 29% of our properties were not Green-certified Assets based on gross floor area. Our target is to continue to maintain the percentage of Green-certified Assets at 70% or more by 2030.

#1 Aligned with E/S characteristics includes the investments of the financial product used to attain the environmental or social characteristics promoted by the financial product.

-The sub-category #1B other E/S characteristics covers investment aligned with the environmental or social characteristics that do not qualify as sustainable investments.

#2 Other includes the remaining investments of the financial product which are neither aligned with the environmental or social characteristics, nor are qualified as sustainable investments.

For any investments that are expected to remain in “#2 Other”, we invest only in properties that have been subjected to ESG-related due diligence review, which measures various environmental indicators of a property and applies relevant safeguards and requirements. We may exclude a future potential investment as a result of the ESG-related due diligence review. We continuously strive to implement environmental measures and obtain environmental certifications for the properties in our portfolio which have not achieved the requisite ranking under BELS, CASBEE, DBJ Green Building Certification or Tokyo Low Carbon Small and Medium-Sized Model Building mentioned above. In January 2022, we set a new target to include Green Clauses in 100% of new lease agreements. We also plan to achieve and maintain the ESG data coverage to cover all of our properties excluding the ones where we only own the land.

Monitoring of environmental or social characteristics

For the purpose of monitoring and tracking our performance on E/S characteristics, we mainly use the following indicators to check the attainment every fiscal period or fiscal year, at both the portfolio level and the property level:

Overall ESG performance. To independently assess the overall ESG performance of our portfolio, we participate in the annual review by the GRESB. We acquired the highest rank “5 stars” for five consecutive years on GRESB Real Estate Assessment, which is based on our GRESB Overall Score and our quintile position relative to global participants. We also were recognized for our high performance both in the “Management Component” that evaluates organizational structure and the “Performance Component” that assesses environmental performance. Further, we achieved for five consecutive years “A rank” in the GRESB Public Disclosure that assesses the width of ESG disclosure.

Climate change initiatives – energy consumption and efficiency: We track and monitor energy use and energy use intensity at our properties, with a particular focus on the areas controlled by ourselves and a medium- to long-term target of 1% average annual reduction in energy use intensity. For the twelve-month period ended March 31, 2023, we have energy use data available for 46 out of all 49 of our properties, and the energy use intensity for the areas of our properties under our operational control of energy consumption was 0.23 MWh/m2.

Climate change initiatives – CO2 / greenhouse gas (“GHG”) emissions: We track and monitor CO2 emissions, calculated in accordance with the "GHG Emissions Accounting, Reporting and Disclosure System" of the Ministry of the Environment. The actual total emission for the twelve-month period ended March 31, 2023 was 31,513 t-CO2, and the emission intensity was 0.06 t-CO2/m3 for total emission (covering direct and indirect emission from the areas of our properties under our operational control, as well as emission from tenants) and 0.073 t-CO2/m3 for direct and indirect emission. In July 2022, we have updated our target related to the key performance indicators (“KPIs”) on renewable energy procurement and our new target is to complete the procurement of renewable electricity by the end of the fiscal year 2025 and to reduce 100% of CO2 emissions generated by electricity in comparison to the fiscal year 2015. This target applies to all of our properties, excluding the co-owned, sectionally owned or land-only properties that have not procured renewable electricity.

Water management initiatives: We monitor and track water consumption and recycling at our properties. Our water consumption intensity is 0.80 m3/m2 for the twelve-month period ended March 31, 2022 and 0.89 m3/m2 for the twelve-month period ended March 31, 2023. We plan to achieve a medium- to long-term target of 0.5% average annual reduction in water use intensity.

Waste management initiatives: We monitor and track waste generated by tenants at our properties. Our waste generation for the twelve-month period ended March 31, 2023 was 2,652 tons, excluding waste directly generated by tenants. We plan to reach a medium- to long-term target of 0.5% average annual reduction in waste intensity.

Social initiatives – employees: We provide several programs to employees in partnership with external organizations, including continued training on asset management operations and legal compliance, as well as management training by GLOBIS, one of the largest business schools in Japan. Management training is provided to senior management and medium-level employees as a part of position-based trainings. Trainings provided to all-levels employees include trainings on communication, business skills, PC skills and business English conversation lessons.

Social initiatives – local community: We donated through Regional Revitalization Support Tax System for three consecutive years from 2020 to 2022, and participated in a fundraising program to the Hokkaido Prefecture. In 2022, we also donated to the Kyoto City’s carbon neutrality program through Regional Revitalization Support Tax System. We periodically participate in cleanups of the neighborhood’s streets organized by an NPO “Green Bird”. We provide open spaces of our Shiodome Building to the “HAMASITE Summer Festival”, a traditional summer event, and created a playground at for kids and a green area on the Seaside Deck for visitors at DECKS Tokyo Beach. At the rooftop terrace of Tokyu Plaza Omotesando Harajuku, we offer a variety of activities to local communities, including bird house installation and vegetable-harvesting. We offer at least one property in our portfolio as disaster prevention or temporary gathering center for nearby local communities.

Social initiatives – tenants: We conduct tenant satisfaction surveys to obtain requests and opinions from our tenants using independent research companies. In the fiscal year 2021, retail tenant surveys were conducted with a significantly increased number of tenants subject to the survey, in addition to the existing office tenant survey participants. We award three times a year a best tenant prize to our retail tenants to encourage operations of all the tenants to raise employee motivations. We also hold customer service competition and training with an ultimate goal of improving customer satisfaction.

Social initiatives – suppliers: We award a prize “PM awards” to property management staff who have contributed to, among others, upward rent revision, lease-up, contracting green lease and implementation of renovation works to reduce environmental impact.

Methodologies

The Asset Manager, TLC REIT Management Inc., has established its Sustainability Policy in 2019 and shares the Tokyu Fudosan Holdings Group’s Sustainability Vision. The Asset Manager’s President & CEO is the Chief Sustainability Officer as well as the Chairman of the Sustainability Promotion Council that meets regularly. A Sustainability Department was also established in 2021 to expand the functionality of the Sustainability Promotion System, which prescribes the organizational structure under which relevant committees, departments, and the Board of Directors interact to promote sustainability initiatives and programs. The review and assessment of material ESG risks and opportunities are built into our investment decision process.

Investment research and investment decision-making. We conduct preliminary investment research to understand how our activities impact material ESG factors and how these can affect our reputation, capital value and stakeholders. Our investment research analyzes various ESG factors such as how we can reduce our environmental load, coexist with local communities where the property is located, contribute to solving social issues, and achieve sustainable growth for all stakeholders. We consider these ESG factors throughout an asset’s lifecycle by tracking and monitoring the sustainability performance of our assets and collaborating with our workforce, partners and communities. The Asset Manager’s Investment Committee considers due diligence findings on ESG factors along with other economic and operational considerations when making a final decision to invest in a property.

Due diligence. Prior to our investment in a property, the Asset Manager conducts due diligence on the property that considers various ESG factors. (i) The Asset Manager investigates the use of asbestos and whether asbestos-containing building materials have been used. The Asset Manager conducts asbestos content testing when existing records and disclosure on the use of asbestos are insufficient, and requires the seller to remove, seal, or contain any remains in accordance with relevant laws on waste disposal and cleaning. (ii) The Asset Manager investigates whether PCB (polychlorinated biphenyl)-containing machines and wastes exist based on information in the property’s records and in the seller’s disclosure and reports. The Asset Manager also requires the seller to investigate whether there are machines with a high possibility of containing PCB, file notifications pursuant to laws on the handling and treatment of PCB, and properly dispose unused PCB-containing machines. (iii) For any company or business with a total annual energy consumption over 1,500 kiloliters of crude oil (after conversion), the Asset Manager investigates what measures are in place to ensure compliance with the Energy Conservation Act, such as whether the property is subject to periodic reports and medium- to long-term plans regarding energy conservation, and whether a manager(s) has been appointed to be responsible for energy management and energy conservation planning. (iv) For any property or facility with a total annual energy consumption over 1,500 kiloliters of crude oil (after conversion) for three consecutive years, the Asset Manager investigates what measures are in place to ensure compliance with the Tokyo Metropolitan Environmental Security Ordinance, including whether the property has a plan for implementing global warming countermeasures. For properties under emission reduction obligations, the Asset Manager would confirm the progress and prospect of meeting the emission reduction targets and deadlines. (v) The Asset Manager investigates potential soil contamination situations through a clear and objective decision-making process with information from reports, seller’s disclosure materials, and field investigations, in order to eliminate the possibility of soil contamination. The Asset Manager requires that any existing soil contamination issue be addressed in accordance with relevant environmental laws.

Green bonds. From time to time, we issue investment corporation bonds earmarked for use in certain projects serving as countermeasures against global warming or providing environmental benefits under our green bond framework (collectively, the “green bonds”), which is generally aligned with the Green Bond Principles, a voluntary guideline of International Capital Market Association. Our green bond framework requires the proceeds from our green bonds to be allocated to funds for (i) acquisition of the “Eligible Green Projects” (as defined below) or (ii) refurbishments fulfilling certain “Eligibility Criteria” (as defined below), or (iii) refinancing the existing loans/investment corporation bonds which have been allocated to acquire Eligible Green Projects or refurbishments meeting Eligibility Criteria. Under our green bond framework, the Eligible Green Projects are defined as buildings that have achieved, or are expected to achieve, the top two levels of one or more of the third-party green building certifications/re-certifications under Building Energy-efficiency Labeling System (“BELS”), Comprehensive Assessment System for Built Environment Efficiency (“CASBEE”) or Development Bank of Japan (“DBJ”) Green Building Certification, within 36 months prior to the payment date of such green bonds. Under our green bond framework, the Eligibility Criteria are defined as refurbishments that have been completed, or are expected to be completed, with a primary purpose of achieving (i) more than 10% reduction in CO2 emissions or energy consumption, (ii) more than 10% reduction in water consumption or (iii) new third-party green building certification or improvement in third-party green building certification required under the Eligible Green Projects, within 36 months prior to the payment date of such green bonds. As of May 31, 2023, 19 properties in our portfolio are Eligible Green Projects, and the aggregate principal amount of our green bonds outstanding is ¥19.4 billion.

Data sources and processing

Environmental certification of individual properties. The Asset Manager obtains the relevant data as provided by the established third-party organizations that issue environmental certifications for the properties in our portfolio. Obtaining the environmental certifications issued by the established third-party organizations helps to ensure the data quality.

Environmental initiatives. At the property level, the Asset Manager collects the relevant data from the property managers. At the portfolio level, the Asset Manager compiles relevant data internally. To ensure data quality, the Asset Manager obtains an assurance report regarding energy consumption, greenhouse gas emissions and water use from an independent third-party organization each year.

Cooperation with property managers. The Asset Manager calculates the relevant data for each property through close contact with property manager at regular meetings and other opportunities. Limitations to methodologies and data

The primary limitation to the methodology or data source is the necessity of our reliance on the tenants and property management companies for raw data at the property level. Like many other real estate investment corporations and asset managers, we rely on raw data provided by the tenants and property management companies, and independent verification of accuracy of such raw data provided by the tenants and property management companies presents challenges. In addition, data at the property level provided by the tenants and property managers is generally updated on an annual basis. Accordingly, property-specific data will therefore not always be fully up to date.

Data at the portfolio level are compiled internally at the Asset Manager. To ensure the accuracy of compiled data at the portfolio level, we have engaged an independent third-party accounting firm which has provided an assurance report regarding the accuracy and quality of compiled data at the portfolio level in accordance with our own criteria and methodologies. However, the assurance report does not provide independent verification of accuracy of raw data at the property level and the challenges associated with our reliance on the tenant and property management companies for raw data at the property level remain.

Limitations to the methodology and data are not expected to affect the attainment of the environmental or social characteristics promoted by API in any material way.

Due diligence

Prior to our investment in a property, the Asset Manager conducts due diligence on the property that considers various ESG factors. (i) The Asset Manager investigates the use of asbestos and whether asbestos-containing building materials have been used. The Asset Manager conducts asbestos content testing when existing records and disclosure on the use of asbestos are insufficient, and requires the seller to remove, seal, or contain any remains in accordance with relevant laws on waste disposal and cleaning. (ii) The Asset Manager investigates whether PCB (polychlorinated biphenyl)-containing machines and wastes exist based on information in the property’s records and in the seller’s disclosure and reports. The Asset Manager also requires the seller to investigate whether there are machines with a high possibility of containing PCB, file notifications pursuant to laws on the handling and treatment of PCB, and properly dispose unused PCB-containing machines. (iii) For any company or business with a total annual energy consumption over 1,500 kiloliters of crude oil (after conversion), the Asset Manager investigates what measures are in place to ensure compliance with the Energy Conservation Act, such as whether the property is subject to periodic reports and medium- to long-term plans regarding energy conservation, and whether a manager(s) has been appointed to be responsible for energy management and energy conservation planning. (iv) For any property or facility with a total annual energy consumption over 1,500 kiloliters of crude oil (after conversion) for three consecutive years, the Asset Manager investigates what measures are in place to ensure compliance with the Tokyo Metropolitan Environmental Security Ordinance, including whether the property has a plan for implementing global warming countermeasures. For properties under emission reduction obligations, the Asset Manager would confirm the progress and prospect of meeting the emission reduction targets and deadlines. (v) The Asset Manager investigates potential soil contamination situations through a clear and objective decision-making process with information from reports, seller’s disclosure materials, and field investigations, in order to eliminate the possibility of soil contamination. The Asset Manager requires that any existing soil contamination issue be addressed in accordance with relevant environmental laws.

Engagement policies

As discussed in detail above, we invest only in properties that have been subjected to ESG-related due diligence review. We may exclude a future potential investment as a result of the ESG-related due diligence review.

Designated reference benchmark

API has no benchmark index designated as a reference benchmark to meet the environmental or social characteristics promoted by API.

REMUNERATION AND SUSTAINABILITY RISKS (SFDR ARTICLE 5 DISCLOSURE)

The Asset Manager has a remuneration policy in place which aims to support its strategy, values and long-term interests, including its interests in the field of sustainability. The Asset Manager’s remuneration policy is consistent with the integration of sustainability risks as follows.

Non-supervisor employees receive monthly remuneration composed of base salary and additional salary based on merit. Such employees also received bonuses and various allowances such as overtime pay (including late-night overtime pay), holiday allowances and commuter allowances.

Supervisors, as defined under the Labor Standard Law of Japan, receive monthly remuneration composed of base salary only. These employees also receive bonuses and late-night overtime pay.

Base salary is determined based on separately established standards that take into consideration market standards, individual abilities and work responsibilities and the ability of the Asset Manager to pay salary. Bonuses are based on each employee’s evaluation and attendance record, and the Asset Manager’s profitability. Employees may be promoted and receive increased base salary and bonuses based on annual personnel evaluations of the previous fiscal year, which includes their relative contribution to and expectations for the achievement of performance targets. In addition, the management and employees are required to include ESG related targets when setting their performance targets, and the Asset Manager evaluates how these ESG related targets are pursued in their operation process and achieved in their work performances, in the same manner as the Asset Manager evaluates the achievement of other targets.

Remuneration, methods of calculation and payment, timing of payment, and increases in remuneration are determined according to the Asset Manager’s compensation rules, which are established based on statutory requirements. Remuneration of secondees is separately agreed upon between the Asset Manager and the companies that employ the secondees.

INTEGRATION OF SUSTAINABILITY RISKS IN THE INVESTMENT DECISIONS, AND THE IMPACT OF SUCH RISKS ON THE RETURNS OF ACTIVIA PROPERTIES INC. (SFDR ARTICLE 6 DISCLOSURE)

We have established the Sustainability Promotion Council, which holds quarterly meetings to deliberate and decide upon matters concerning the promotion of ESG such as passing resolutions for basic ESG policies, annual plans for ESG promotion, annual activities planning and reporting, and initiatives for various ESG measures under our portfolio management strategy. At these meetings, the Sustainability Department will make proposals on specific steps toward implementing and achieving ESG goals to the members of the Council, which includes directors (excluding part-time directors), chief division officers of all of the divisions, general managers of the Environmental Engineering Department and Sustainability Department, and the compliance officer. The President & CEO of the Asset Manager serves as the Chief Sustainability Officer as well as the Chairman of the Sustainability Promotion Council, and has the authority to make final decisions on such proposals.

In order to realize sustainability in our asset management and to maximize the value of our portfolio assets, we have emphasized taking ESG factors into consideration concerning our investment and asset management processes. The Asset Manager has established the green bond framework in order to expand financing methods and to enhance the development of green finance. Specifically, we have committed to use the green bonds exclusively for the properties that qualifies under the green qualification criteria that we have. Under this organizational structure, we have instituted a number of initiatives, at both the portfolio level and the property level, to promote E/S characteristics. Such initiatives include climate change initiatives, water resources and waste management initiatives, local community initiatives, and tenant and employee initiatives. We believe that integrating sustainability factors alongside traditional financial and operational metrics in our investment decision process helps us make a more holistic assessment of a property’s risks and opportunities and is commensurate with the pursuit of superior risk-adjusted returns.

Environmental Risks

Potential Changes in Business Environment Emerging Risks Our Understanding Potential Countermeasures
Acceleration of climate change – transition risks (policies, laws & regulations)

Increased pricing of GHG emissions

Cost arising from carbon tax levy

The introduction of a high carbon tax designed to curb CO2 emissions in Japan is likely to mean higher operational costs stemming from, for example, a heavier tax burden on CO2 emissions from proprietary properties. Stricter environmental regulations with regard to ZEBs, energy saving standards, and the like are likely to translate into additional costs of refurbishments needed to comply with them. Tighter regulations will have a tremendous impact on tenants’ choice of properties. It is expected that in comparing properties of different real estate agencies, demand for properties with lower energy efficiency will decline. With an eye on a transition to a decarbonized society under the scenarios of below 2℃, we are committed to addressing these risks and maintaining our competitive edge. To these ends, we will take a number of actions. These include deploying renewables, switching over to LED lighting in a systematic manner, and retrofitting our properties with more energy efficient equipment. To make our portfolio greener, we will also increase the proportions of environmentally certified properties and green lease agreements with new tenants.

Mandates on and regulation of existing products and services

Increased construction costs arising from compliance with ZEB-related and other environmental regulations

Acceleration of climate change – physical risks Increased severity of extreme weather events Costs incurred from the need to address torrential rain disasters, etc.

We expect damage to our proprietary properties due to increased severity of extreme weather events and resultant increases in repair expenses. It is worth noting here that our buildings are originally disaster-resistant and that our investment focuses on properties in areas resistant to inundation and other risks. With regard to chronic changes such as rising mean temperatures, we are committed to reducing CO2 emissions by, for example, deploying renewables and considering and replacing existing key equipment such as electric and air conditioning equipment with more energy-efficient equipment wherever possible when it reaches its end of life.

Large-scale earthquakes Severe human and asset damages caused by earthquakes We are likely exposed to the risk of physical damage to our properties and damage to our tenants in the event of an unprecedented large earthquake.

As earthquakes happen frequently in Japan, we monitor the PML (Probable Maximum Loss) of every property and the portfolio as a whole, reported and updated by third-party experts, and we have earthquake and property insurance to hedge the risk.


When a large earthquake occurs, the Asset Manager will promptly implement disaster emergency and business continuity planning measures, collaborate with the property manager to confirm and keep the safety of the tenants.

Social Risks

Potential Changes in Business Environment Emerging Risks Our Understanding Potential Countermeasures
Human capital development as a group of professionals becoming more important Lack of sufficient skilled human resources Lack of sufficient skilled human resources may hinder business operation, leading to stagnant or lower investor values.

The Asset Manager implements the following policies: (i) Promotion of human resource strategy that indicates the requirements of desirable resources and facilitate development; (ii) Commitment to health and well-being of each employee; and (iii) Deployment of measures based on Tokyu Fudosan Holdings Group’s KPIs (such as work-style reform and promotion of diversity)


Below are the status and examples of the implementation of the Asset Manager’s policies: (i) Disclosure of key employee data to present our human resources strategy and status of efforts on employee health and well-being (such as ratio of female employees, number of female directors and managers, turnover ratio and stress check participation ratio); (ii) Supporting acquisition of business knowledge, skills and qualifications, and implementation of various trainings; (iii) Promotion of career development through periodic performance evaluation and feedback; (iv) Periodic meetings of the Health Committee; and (v) Introduction of various support systems leveraging on the benefits such as Tokyu Group membership.

Unpredictable Infectious Diseases Social and economic losses due to potential unpredictable pandemic diseases Our investment results may be impacted by social changes and/or economic declines, which may be caused by pandemic diseases.

We will maintain/improve our plans to minimize the potential impact of any future pandemic through various measures such as property sanitation and programs to raise tenant awareness. In addition, to prevent infection among its management and employees, the Asset Manager has introduced remote work environment for some of its business operation.

SUSTAINABILITY-RELATED DISCLOSURE

Product Name: Comforia Residential REIT, Inc.

Legal Entity Identifier: 353800BJ2SV3UPG9JU05

Comforia Residential REIT, Inc (“CRR”) promotes environmental or social characteristics, but does not have as its objective a sustainable investment within the meaning of Article 9(1) of Regulation (EU) 2019/2088 (“SFDR”). CRR does not have any employees in accordance with the prohibition on having employees under the Act on Investment Trusts and Investment Corporations of Japan, and CRR relies on TLC REIT Management Inc. (the “Asset Manager”) to manage and operate the properties in the portfolio. CRR and the Asset Manager are hereinafter referred to collectively as “we,” “us” or “our”. References to “fiscal year” are to the 12 months began or beginning February 1 of the year, and references to “fiscal period” are to the 6 months began or beginning February 1 or August 1 of the year, unless noted otherwise.

Summary

No sustainable investment objective

The financial products offered by CRR promote environmental or social characteristics, but do not have as its objective sustainable investment.

Environmental or social characteristics of the financial product

CRR and the Asset Manager promote Environmental / Social characteristics through a host of environmental, social and governance enhancement initiatives, aligned with the United Nations’ 17 Sustainability Development Goals (“SDGs”). Specifically, we implement various environmental initiatives at our properties including those against climate change, supporting local communities, tenants, employees, and public health.

As a member of the Tokyu Fudosan Holdings Group, which is a leading real estate developer specialized in providing best-in-class retail, office, residential, entertainment, and lifestyle properties and facilities in various countries in a more sustainable way, we all share the same approach to sustainability and work together to promote sustainability in our business practices.

Investment strategy

The Asset Manager has established its Sustainability Policy in April 2019 and shares the Tokyu Fudosan Holdings Group’s Sustainability Vision. Sustainability Department was also established as of April 1, 2021 to expand the functionality of the Sustainability Promotion System, which prescribes the organizations structure under which relevant committees, departments, and the board of directors interact to promote sustainability initiatives and programs. The review and assessment of material ESG risks and opportunities are built into our investment decision process.

We ensure the investment strategy is implemented on a continuous basis by incorporating review and assessment of material ESG-related risks and opportunities into our investment decision process. As discussed in detail below, we consider ESG-related due diligence review before investing in properties.

Proportion of investments

We utilize the top three third-party green building certifications BELS, CASBEE, and DBJ Certification for environmental certifications to categorize the properties in CRR’s portfolio. Through tracking and monitoring these property -level certifications, we assess the overall environmental performance of our whole portfolio environment.

We consider a property as “Green-certified” if it acquires one or more stars in any of the three certifications mentioned above. We call our property that receives any such certifications as “Green-certified Assets”. As of July 31, 2023, approximately 24.4% of the properties in our portfolio based on gross floor area were green-certified. As to the other properties not green-certified so far, we plan to acquire applicable certification for one to two properties annually in order to increase the percentage of the Green-certified Assets in our portfolio to 40% based on gross floor area by FY2030.

Monitoring of environmental or social characteristics

For the purpose of monitoring and tracking our performance on Environmental /Social characteristics, we mainly use specific indicators to check the attainment every fiscal period or fiscal year, at both the portfolio level and the property level.

The following are our key performance indicators: Overall ESG performance; Climate change initiatives - Environmental certification/Greenhouse gas (“GHG”) emissions/Energy consumption intensity/Water Consumption management/Other ESG data Coverage; and Social initiatives -Local community/Tenants.

Methodologies

Asset Manager’s Sustainability Promotion Council holds quarterly meetings to deliberate and decide upon matters concerning the promotion of ESG such as passing resolutions for basic ESG policies, annual plans for ESG promotion, annual activities planning and reporting, and initiatives for various ESG measures under our portfolio management strategy. We have instituted a number of initiatives, at both the portfolio level and the property level, to promote Environmental /Social characteristics including climate change initiatives, local community initiatives, and tenant and employee initiatives.

Data sources and processing

The Asset Manager obtains certain ESG-related data from third-party consulting firms, issuers of environmental certifications, property managers, other service providers and tenants, depending on the type of data. The Asset Manager seeks to ensure data quality by engaging established third-party service providers. Also, the Asset Manager obtains an assurance report regarding energy consumption, GHG emissions and water use from an independent third-party organization each year, which helps to ensure data quality.

Limitations to methodologies and data

The primary limitation to the methodology or data source is the necessity of our reliance on the tenants and property management companies for raw data at the property level. In addition, data at the property level provided by the tenants and property managers is generally updated on an annual basis. Accordingly, property-specific data will therefore not always be fully up to date.

However, limitations to the methodology and data are not expected to affect the attainment of the environmental or social characteristics promoted by CRR in any material way.

Due diligence

Prior to investment in a property, the Asset Manager conducts due diligence on the property that considers various ESG factors such as: (i) use of asbestos-containing building materials; (ii) PCB (polychlorinated biphenyl)-containing machines and wastes existence; (iii) annual energy consumption of any company or business; (iv) annual energy consumption of any property or facility; and (v) potential soil contamination.

Engagement policies

As discussed in detail above, we invest only in properties that have been subjected to ESG-related due diligence review. We may exclude a future potential investment as a result of the ESG-related due diligence review. In addition, we do not invest in real estate assets involved in the extraction, storage, transport, or manufacture of fossil fuels.

Designated reference benchmark

CRR has no benchmark index designated as a reference benchmark to meet the environmental or social characteristics promoted by CRR.

No sustainable investment objective

The financial products offered by CRR promote environmental or social characteristics, but do not have as its objective sustainable investment.

Environmental or social characteristics of the financial product

For the existing residential properties in CRR’s portfolio, we promote E/S characteristics through a host of environmental, social and governance (“ESG”) enhancement initiatives, aligned with the United Nations’ 17 Sustainability Development Goals (“SDGs”). Specifically, we implement various environmental initiatives at our properties including those against climate change (installation of green space highlighting the natural environment in accordance with the Ordinance for the Conservation and Restoration of Nature in Tokyo, installation of solar panels on the rooftops for renewable energy usage, energy-efficient glass panels for windows, windowed entrances to make use of natural daylight, replacement of LED lights in common areas and air conditioning units in private areas to reduce power consumption and environmental impact, and introduction of bicycle/scooter sharing space/services to contribute to smart city planning, carbon dioxide reduction and citizen health. Our environmental initiatives are aligned with the SDG Target 7.3 (By 2030, double the global rate of improvement in energy efficiency), 12.5 (By 2030, substantially reduce waste generation through prevention, reduction, recycling, and reuse) and 12.8 (By 2030, ensure that people everywhere have the relevant information and awareness for sustainable development and lifestyles in harmony with nature).

Our social initiatives include supporting local communities (collaborating with local communities on measures against natural disasters, including installation of donation-type vending machines, establishment of a warehouse for provision in disasters and manhole toilets, entry into an emergency mutual assistance agreement with three neighboring town councils, and donation to local communities through Regional Revitalization Support Tax System and participating in cleanups events of neighborhoods), tenants (tenant satisfaction surveys conducted every year, multi-lingual guide maps displayed at one of our properties for tenants from overseas, and holding tenant-participating events), employees (supporting work-style reform such as paid leave and remote work, promoting workplace/worktime diversity, implementing training programs, and supporting certification acquisition by the Asset Manager’s employees), and public health (putting up posters informing infection prevention measures to raise tenants’ awareness and placing alcohol-based hand sanitizers in every property’s entrance area). Our social initiatives are aligned with the SDG Target 11.3 (By 2030, enhance inclusive and sustainable urbanization and capacity for participatory, integrated and sustainable human settlement planning and management in all countries) and 12.8 (By 2030, ensure that people everywhere have the relevant information and awareness for sustainable development and lifestyles in harmony with nature).

CRR has no employees in accordance with the prohibition on having employees under the Act on Investment Trusts and Investment Corporations of Japan, thus relying on the Asset Manager to manage and operate the properties in our portfolio. We and the Asset Manager believe that residential properties have potential to contribute to resolving environmental and societal issues in Japan, such as by taking appropriate actions against climate change, and promoting sustainable cities and community connections.

The Asset Manager, TLC REIT Management Inc., is a subsidiary of the Tokyu Land Corporation and a part of the Tokyu Fudosan Holdings Group. Tokyu Fudosan Holdings Group, we and the Asset Manager all share the same approach to sustainability and work together to promote sustainability in our businesses. As a leading provider to the Japanese and world real estate market, the Tokyu Fudosan Holdings Group is uniquely positioned to develop best-in-class retail, office, residential, entertainment, and lifestyle properties and facilities in various countries in a more sustainable way. Incorporating the Tokyu Fudosan Holdings Group’s ESG policy statement, we aim to integrate sustainability into the heart of our business practices, underpinned by the following ESG principles:

Building businesses and investing responsibly – We embed ESG into our investment and decision-making processes by understanding how our activities impact material ESG factors and thereby affect our reputation, capital value and stakeholders, focusing on how we can best manage our workforce, whether it is the Asset Manager’s own employees or our tenants, contractors and suppliers, and recognizing how we can work with the communities where we invest and operate businesses and how we can enhance our presence through economic development, limiting our environmental impact, and seeking a community’s license to operate.

Developing and managing sustainable assets – We consider ESG impact throughout an asset’s lifecycle by empowering the Asset Manager’s asset management teams to prioritize, act, track and monitor the sustainability performance of our assets and in certain instances collaborate with our tenants, partners, and communities. Green Procurement Standards have been established and adopted to guide usage of environment-friendly/energy-efficiency construction materials/facilities for all properties. Especially, the green procurement list has been used in bid specifications for Large-scale repair work.

Improving efficiency and enhancing value – Our mission is to build sustainable businesses and generate attractive risk-adjusted returns to our unitholders over the long term, while providing value-adding investment and operational services. Digital technologies will allow us to increase work efficiency and expand the circle of satisfaction. Specifically, digital transformation initiatives can help advance workstyle reform, implement HR strategies such inclusion and diversity, and improve customer experience. These will ultimately contribute to achieving a sustainable society and company governance.

Governing with high ethics and transparency – We are committed to maintaining the highest standards of corporate governance and adopting an evolving suite of governance practices. Ethical governance standards and practices are woven into the fabric of our business as a means of enhancing corporate performance, accountability, and our unitholder value. We continuously review and refine our processes in light of best practice, consistent with our needs and circumstances, maintain a zero-tolerance approach to bribery and corruption, and require all management and the Asset Manager’s employees to comply with our code of business conduct at all times.

Promoting well-being – We aim to incorporate health and well-being throughout our organization and assets in support of our tenants and the Asset Manager’s employees, and the communities in which they work. We focus on promoting well-being concepts such as working-style reform, implementing welfare programs such as childcare leaves and financial planning, and creating a working environment that promote comfort, health, and social life.

Investment strategy

CRR invests directly or indirectly through trust beneficiary interests in real estate and real estate-related assets. Therefore, due diligence review (including the assessment of good governance practices) in relation to investee companies is not applicable. Therefore, we have opted to provide information on the governance policies adopted by CRR and the Asset Manager. The investment policies as described below are related to real estate and real estate-related assets.

The Asset Manager, TLC REIT Management Inc., has established its Sustainability Policy in April 2019 and shares the Tokyu Fudosan Holdings Group’s Sustainability Vision. The Asset Manager’s President & CEO is the Chief Sustainability Officer as well as the Chairman of the Sustainability Promotion Council that meets regularly. A Sustainability Department was also established as of April 1, 2021 to expand the functionality of the Sustainability Promotion System, which prescribes the organizations structure under which relevant committees, departments, and the board of directors interact to promote sustainability initiatives and programs. The review and assessment of material ESG risks and opportunities are built into our investment decision process.

Investment research and investment decision-making. We conduct preliminary investment research to understand how our activities impact material ESG factors and how these can affect our reputation, capital value and stakeholders. Our investment research analyzes various ESG factors such as how we can reduce our environmental load, coexist with local communities where the property is located, contribute to solving social issues, and achieve sustainable growth for all stakeholders. We consider these ESG factors throughout an asset’s lifecycle by tracking and monitoring the sustainability performance of our assets and collaborating with our workforce, partners and communities. The Asset Manager’s Investment Committee considers due diligence findings on ESG factors along with other economic and operational considerations when making a final decision to invest in a property.

Green bonds. From time to time, we issue investment corporation bonds earmarked for use in certain projects serving as countermeasures against global warming or providing environmental benefits under our green bond framework (collectively, the “green bonds”), which is generally aligned with the Green Bond Principles, a voluntary guideline of International Capital Market Association. Our green bond framework requires the proceeds from our green bonds to be allocated to funds for (i) acquisition of the “Eligible Green Projects” (as defined below) or (ii) refurbishments fulfilling certain “Eligibility Criteria” (as defined below), or (iii) refinancing the existing loans/investment corporation bonds which have been allocated to acquire Eligible Green Projects or refurbishments meeting Eligibility Criteria. Under our green bond framework, the Eligible Green Projects are defined as buildings that have achieved, or are expected to achieve, the top three levels of one or more of the third-party green building certifications/re-certifications under Building Energy-efficiency Labeling System (“BELS”), Comprehensive Assessment System for Built Environment Efficiency (“CASBEE”) or Development Bank of Japan (“DBJ”) Green Building Certification, within 36 months prior to the payment date of such green bonds. Under our green bond framework, the Eligibility Criteria are defined as refurbishments that have been completed, or are expected to be completed, with a primary purpose of achieving (i) more than 20% reduction in energy consumption or water consumption, (ii) new third-party green building certification or improvement in third-party green building certification required under the Eligible Green Projects, within 36 months prior to the payment date of such green bonds. As of July 31, 2023, nine properties in our portfolio were Eligible Green Projects, and the aggregate principal amount of our green bonds outstanding was ¥4.5 billion.

We ensure the investment strategy is implemented on a continuous basis by incorporating review and assessment of material ESG-related risks and opportunities into our investment decision process. As discussed in detail above, we consider ESG-related due diligence review before investing in properties.

While there is no third-party rating used for assessment of our governance practices, we have introduced the following measures to assess and enhance our governance systems:

Adoption of performance-linked asset management fees. We pay performance-linked fees based on our earnings to the Asset Manager in order to align the interest of our unitholders with that of the Asset Manager.

Alignment of interests of our unitholders and the Sponsor,Tokyu Land Corporation. In the Sponsor Support Agreement, Tokyu Land Corporation has expressed that if and when CRR decides to issue additional units, Tokyo Land Corporation will consider in good faith whether to subscribe any such units. We aim to build a strong relationship with the Sponsor and align the interest of our unitholders with that of the Sponsor.

Acquisition process ensuring fairness and guarding unitholder interests. The Asset Manager has a decision-making process based on internal regulations. Asset acquisition from related parties requires deliberation and resolution of the Compliance Committee of the Asset Manager, which includes external experts, and deliberation and resolution of the Investment Committee of the Asset Manager, before asset acquisition from related parties is submitted to the board of directors of CRR.

Measures to enhance compliance. The Compliance Committee and the Compliance Department of the Asset Manager, TLC REIT Management Inc., ensure we carry out our business in compliance pursuant to the Tokyu Fudosan Holdings Group’s Code of Conduct. The framework is reinforced by the Rules on the Compliance and the Compliance Manual. Each year divisional compliance staff are appointed from each division to perform periodic monitoring on compliance matters and report and share compliance status of each division. We provide compliance training two times a year to our officers and employees, and TLC REIT Management Inc. has a Compliance Helpline Counter as a contact point for consulting, direct reporting to senior compliance officers, and the protection of whistleblowers.

Transparent and appropriate information disclosure. We hold management call meetings for our overseas unitholders and provide earnings presentations to a wide range of unitholders via teleconference. We make press releases and other disclosures in both Japanese and English simultaneously.

Proportion of investments

We utilize the top three third-party green building certifications BELS, CASBEE, and DBJ Certification for environmental certifications to categorize the properties in CRR’s portfolio. Through tracking and monitoring these property -level certifications, we assess the overall environmental performance of our whole portfolio environment.

We consider a property as “Green-certified” if it acquires one or more stars in any of the three certifications mentioned above. We call our property that receives any such certifications as “Green-certified Assets”. As of July 31, 2023, approximately 24.4% of the properties in our portfolio based on gross floor area were green-certified. As to the other properties not green-certified so far, we plan to acquire applicable certification for one to two properties annually in order to increase the percentage of the Green-certified Assets in our portfolio to 40% based on gross floor area by FY2030.

#1 Aligned with E/S characteristics includes the investments of the financial product used to attain the environmental or social characteristics promoted by the financial product.

-The sub-category #1B other E/S characteristics covers investment aligned with the environmental or social characteristics that do not qualify as sustainable investments.

#2 Other includes the remaining investments of the financial product which are neither aligned with the environmental or social characteristics, nor are qualified as sustainable investments.

The investments under “#2 Other” are those properties have not been “green-certified” so far. As we always invest in properties that have been subjected to ESG-related due diligence review, which measures various environmental indicators of a property and applies relevant safeguards and requirements.

We continuously strive to implement environmental measures and obtain environmental certifications for the properties in our portfolio which have not achieved the requisite ranking under BELS, CASBEE, or DBJ Green Building Certification mentioned above, as our goal is to acquire certification for one to two properties annually to continue increasing the percentage of Green-certified assets. As a result, we expect some of the investments under “#2 Other” to eventually become investments under “#1 Aligned with E/S”.

For any investments that are expected to remain in “#2 Other”, we make efforts to reduce their environmental impact through renovations to reduce power consumption, such as switching to LED lights in the common areas, replacement of old air-conditioning units in the areas exclusively occupied by tenants, using eco-friendly reform or renovation materials such as recyclable tile carpets, and other work to enhance energy efficiency.

Monitoring of environmental or social characteristics

For the purpose of monitoring and tracking our performance on E/S characteristics, we mainly use the following indicators to check the attainment every fiscal period or fiscal year, at both the portfolio level and the property level.

Overall ESG performance. To independently assess the overall ESG performance of our portfolio, we participate in the annual review by Global Real Estate Sustainability Benchmark (“GRESB”). In 2021 and 2022, we acquired “2 Stars” in GRESB rating (calculated based on our GRESB overall score and our quintile position relative to global participants), a benchmarking assessment that evaluates sustainability performance of investment companies managing leased properties. In 2021 and 2022, we additionally acquired “Green Star” designation by achieving high performance both in the management component, which evaluates policies and organizational structure for ESG promotion, and the performance component, which assesses environmental performance and tenant engagement of properties. We will continue to aim for higher sustainability performance in our properties by implementing environmental and energy-saving measures and increasing efficiency of energy use, in collaboration with the property managers and other parties.

Climate change initiatives - Environmental certification. We utilize certain environmental certifications issued by third party organizations to monitor and track the ESG performance at the building level. As of July 31, 2023, approximately 24.4% of the properties in our portfolio had acquired such environmental certification based on gross floor area. As announced in our Sustainability Report 2022, we aim to increase the percentage of our properties with the environmental certifications to 40% based on gross floor area by FY2030. In addition, we use these environmental certifications to determine eligibility of acquisitions of new properties or refurbishments of existing properties for using proceeds of certain investment corporation bonds earmarked for serving as countermeasures against global warming or providing environmental benefits.

Climate change initiatives - Greenhouse gas (“GHG”) emissions . We track and monitor GHG emissions intensity, calculated in accordance with the GHG Emissions Accounting, Reporting and Disclosure System established by the Ministry of the Environment of Japan, and aim to reduce the CO2 emissions intensity of our properties by 40% by FY2030 compared to the level in FY2020. Total GHG emissions intensity of our properties was 0.036 t-CO2/m2 (in FY2020), 0.036 t-CO2/m2 (in FY2021) and 0.036 t-CO2/m2 (in FY2022).

Climate change initiatives - Energy consumption intensity. We track and monitor energy use and energy use intensity with a particular focus on the common areas controlled by ourselves and aim to achieve a medium- to long-term target of 1% average annual reduction in energy use intensity in our portfolios. Specifically, in order to increase the electric power consumption coverage rate at our properties, electric power measuring systems have been installed at four properties as of July 31, 2023, making it possible to measure power consumption at areas exclusively owned by us. Energy consumption intensity of our properties was 0.091 MWh/m² (in FY2020), 0.092 MWh/m² (in FY2021) and 0.093 MWh/m² (in FY2022).

Climate change initiatives -Water Consumption management. We monitor and track water consumption at our properties and make efforts to meet the criteria for the “Eligible Green Projects” (as defined below) with respect to water consumption intensity in common areas. The water consumption intensity of the common area in our properties is 0.406 m3/m2(in FY2020), 0.283 m3/m2 (in FY2021), and 0.300 m3/m2 (in FY2022).

Climate change initiatives – Other ESG data Coverage. We have been kept recording and reporting the daily waste volume at two properties from March 2021 and monitoring the recycle rate based on the waste weight, and the properties under monitoring increased to 15 properties as of July 31, 2023.

Social initiatives – Local community. The Asset Manager donated through Regional Revitalization Support Tax System for three consecutive years. From 2020, we have participated in a fundraising program in Hokkaido Prefecture, where we own two properties. In 2022, we also donated to the Kyoto City’s SDGs Future City Promotion Plan, as we own one property in Kyoto. We periodically participate in cleanups of the neighborhood’s streets organized by an NPO “Green Bird”. To improve the safety of the residents of our properties and local communities, we have installed vending machines at some of our properties that can provide free drinks as relief supplies to victims of strong earthquakes, typhoons, and other natural disasters. In addition, COMFORIA SHINJUKU EASTSIDE TOWER has been designated by the Shinjuku ward of Tokyo as a property with a disaster provision warehouse and manhole toilets to be used in times of disasters not only for its residents but also for neighboring residents and workers. We have also entered into an emergency mutual assistance agreement with three neighboring town councils to enforce local collaboration.

Social initiatives – Tenants. We conduct annual tenant satisfaction surveys to obtain requests and opinions from our tenants, including on the Comforia brand as well as our management and operation. An example of improvement made based on such surveys is the increase in the number of delivery lockers, which have grown in demand due to the recent rise of e-commerce.

Methodologies

To promote the initiative for sustainability and ESG-related mission in the management of the portfolio, Asset Manager’s Sustainability Promotion Council holds quarterly meetings to deliberate and decide upon matters concerning the promotion of ESG such as passing resolutions for basic ESG policies, annual plans for ESG promotion, annual activities planning and reporting, and initiatives for various ESG measures under our portfolio management strategy.

We have instituted a number of initiatives, at both the portfolio level and the property level, to promote E/S characteristics. Such initiatives include climate change initiatives, local community initiatives, and tenant and employee initiatives.

Climate change initiatives. The key drivers of our climate change initiatives are energy-saving and emissions reduction. We set a medium- to long-term target of 1% average annual reduction in energy use intensity and in greenhouse gas emissions. At the properties we own and operate, we strive to reduce our environmental load through initiatives such as installation of green space highlighting the natural environment, installation of solar panels on the rooftops for renewable energy usage, energy-efficient glass panels for windows, windowed entrances to make use of natural daylight, replacement of LED lights in common areas and air conditioning units in private areas to reduce power consumption and environmental impact, and introduction of bicycle/scooter sharing space/services to contribute to smart city planning, carbon dioxide reduction and citizen health.

Environment Management System. We have adopted a unique environment management system that applies the plan-do-check-act cycle. The Asset Manager’s Asset Management Department reviews actual performances in its monthly meeting and reports the results to the management once a year, then receives feedbacks and instructions for further improvement for the following year, from the management.

Green lease provisions. To reduce our properties’ environmental load, we insert and emphasize green lease provisions in lease contracts related to energy use and disposal of waste to all the tenants. We seek to include green lease provisions in new as well as renewed lease contracts with our tenants. In addition, we conduct air-conditioner temperature setting change in the common space, and common area light turning-down in some properties to raise our tenants’ awareness of energy-saving.

Local community initiative. Based on our sustainable investment strategy, we donate to and collaborate with local communities on natural disaster and infectious disease prevention efforts. At some of the properties, we have begun to introduce bicycle/scooter sharing space/services to provide convenient and healthy transportation vehicles to the residents living in and nearby our properties, making the connection to local station or neighborhood faster and closer, and contribute to the smart city planning of Tokyo.

Tenant and employee initiatives. We provide convenient amenities to our tenants at some of our properties and conduct tenant satisfaction surveys annually. For our employees, we support work-style reform such as paid leave and remote work, promote workplace/worktime diversity, implement training programs, and support certification acquisition by the Asset Manager's employees.

Data sources and processing

Environmental certification of individual properties. The Asset Manager obtains the relevant data provided by the established third-party organizations that issue environmental certifications for the properties in our portfolio. Obtaining the environmental certifications issued by the established third-party organizations helps to ensure the data quality.

Environmental initiatives. At the property level, the Asset Manager collects the relevant data from the property managers. At the portfolio level, the Asset Manager compiles relevant data internally. To ensure data quality, the Asset Manager obtains an assurance report regarding energy consumption, greenhouse gas emissions and water use from an independent third-party organization each year.

Cooperation with property managers. The Asset Manager calculates the relevant data for each property through close contact with property manager at regular meetings and other opportunities. The Asset Manager can confirm the accuracy of the tracked data by referencing the raw data.

Limitations to methodologies and data

The primary limitation to the methodology or data source is the necessity of our reliance on the tenants and property management companies for raw data at the property level. Like many other real estate investment corporations and asset managers, we rely on raw data provided by the tenants and property management companies, and independent verification of accuracy of such raw data provided by the tenants and property management companies presents challenges. In addition, data at the property level provided by the tenants and property managers is generally updated on an annual basis. Accordingly, property-specific data will therefore not always be fully up to date.

Data at the portfolio level are compiled internally at the Asset Manager. To ensure the accuracy of compiled data at the portfolio level, we have engaged an independent third-party accounting firm which has provided an assurance report regarding the accuracy and quality of compiled data at the portfolio level in accordance with our own criteria and methodologies. However, the assurance report does not provide independent verification of accuracy of raw data at the property level and the challenges associated with our reliance on the tenant and property management companies for raw data at the property level remain.

Limitations to the methodology and data are not expected to affect the attainment of the environmental or social characteristics promoted by CRR in any material way.

Due diligence

Prior to investment in a property, the Asset Manager conducts due diligence on the property that considers various ESG factors.

(i) The Asset Manager investigates the use of asbestos and whether asbestos-containing building materials have been used. The Asset Manager conducts asbestos content testing when existing records and disclosure on the use of asbestos are insufficient, and requires the seller to remove, seal, or contain any remains in accordance with relevant laws on waste disposal and cleaning.

(ii)The Asset Manager investigates whether PCB (polychlorinated biphenyl)-containing machines and wastes exist based on information in the property’s records and in the seller’s disclosure and reports. The Asset Manager also requires the seller to investigate whether there are machines with a high possibility of containing PCB, file notifications pursuant to laws on the handling and treatment of PCB, and properly dispose unused PCB-containing machines.

(iii)For any company or business with a total annual energy consumption over 1,500 kiloliters of crude oil (after conversion), the Asset Manager investigates what measures are in place to ensure compliance with the Energy Conservation Act, such as whether the property is subject to periodic reports and medium- to long-term plans regarding energy conservation, and whether a manager(s) has been appointed to be responsible for energy management and energy conservation planning.

(iv)For any property or facility with a total annual energy consumption over 1,500 kiloliters of crude oil (after conversion) for three consecutive years, the Asset Manager investigates what measures are in place to ensure compliance with the Tokyo Metropolitan Environmental Security Ordinance, including whether the property has a plan for implementing global warming countermeasures. For properties under emission reduction obligations, the Asset Manager would confirm the progress and prospect of meeting the emission reduction targets and deadlines.

(v)The Asset Manager investigates potential soil contamination situations through a clear and objective decision-making process with information from reports, seller’s disclosure materials, and field investigations, in order to eliminate the possibility of soil contamination. The Asset Manager requires that any existing soil contamination issue be addressed in accordance with relevant environmental laws.

Engagement policies

As discussed in detail above, we invest only in properties that have been subjected to ESG-related due diligence review. We may exclude a future potential investment as a result of the ESG-related due diligence review.

In addition, we do not invest in real estate assets involved in the extraction, storage, transport, or manufacture of fossil fuels.

Designated reference benchmark

CRR has no benchmark index designated as a reference benchmark to meet the environmental or social characteristics promoted by CRR.

REMUNERATION AND SUSTAINABILITY RISKS (SFDR ARTICLE 5 DISCLOSURE)

The Asset Manager has a remuneration policy in place which aims to support its strategy, values and long-term interests, including its interests in the field of sustainability. The Asset Manager’s remuneration policy is consistent with the integration of sustainability risks as follows.

Non-supervisor employees receive monthly remuneration composed of base salary and additional salary based on merit. Such employees also received bonuses and various allowances such as overtime pay (including late-night overtime pay), holiday allowances and commuter allowances.

Supervisors, as defined under the Labor Standard Law of Japan, receive monthly remuneration composed of base salary only. These employees also receive bonuses and late-night overtime pay.

Base salary is determined based on separately established standards that take into consideration market standards, individual abilities and work responsibilities and the ability of the Asset Manager to pay salary. Bonuses are based on each employee’s evaluation and attendance record, and the Asset Manager’s profitability. Employees may be promoted and receive increased base salary and bonuses based on annual personnel evaluations of the previous fiscal year, which includes their relative contribution to and expectations for the achievement of performance targets, including sustainability targets.

Remuneration, methods of calculation and payment, timing of payment, and increases in remuneration are determined according to the Asset Manager’s compensation rules, which are established based on statutory requirements. Remuneration of secondees is separately agreed upon between the Asset Manager and the companies that employ the secondees.

INTEGRATION OF SUSTAINABILITY RISKS IN THE INVESTMENT DECISIONS, AND THE IMPACT OF SUCH RISKS ON THE RETURNS OF COMFORIA RESIDENTIAL REIT, INC. (SFDR ARTICLE 6 DISCLOSURE)

The Asset Manager have established the Sustainability Promotion Council, which holds quarterly meetings to deliberate and decide upon matters concerning the promotion of ESG such as passing resolutions for basic ESG policies, annual plans for ESG promotion, annual activities planning and reporting, and initiatives for various ESG measures under our portfolio management strategy. At these meetings, the Sustainability Department will make proposals on specific steps toward implementing and achieving ESG goals to the members of the Council, which includes directors (excluding part-time directors), chief division officers of all the divisions, general managers of the Environmental Engineering Department and Sustainability Department, and the compliance officer. President & CEO of the Asset Manager serves as the Chief Sustainability Officer as well as the Chairman of the Sustainability Promotion Council and has the authority to make final decisions on such proposals.

For the purpose of realizing sustainability in our asset management and to maximize the value of our portfolio assets, we have emphasized taking ESG factors into consideration concerning our investment and asset management processes. The Asset Manager has established the green bond framework in order to expand financing methods and to enhance the development of green finance. Specifically, we have committed to use the green bonds exclusively for the properties that qualifies under one of the green qualification criteria or sustainability qualification criteria that we have.

Under this organizational structure, we have instituted a number of initiatives, at both the portfolio level and the property level, to promote E/S characteristics. Such initiatives include climate change initiatives, water resources and waste management initiatives, local community initiatives, and tenant and employee initiatives.

We believe that integrating sustainability factors alongside traditional financial and operational metrics in our investment decision process helps us make a more holistic assessment of a property’s risks and opportunities and is commensurate with the pursuit of superior risk-adjusted returns.

Environmental Risks

Potential Changes in Business Environment Emerging Risks Our Understanding Potential Countermeasures
Acceleration of Climate Change and Extreme Weather

Rise of Sea Level

A small portion of our properties located close to coastal areas may be damaged by potential floods, which may be magnified by the rising sea levels.

We assess the risk for each of our properties, and also the whole portfolio by analyzing hazard maps issued by local authorities, and by conducting due diligence review including analyzing flood risk when considering investment. .

Outbreak of Abnormal Weather

Our properties may be severely damaged due to massive natural disasters such as super typhoons and ultra-heavy rainfalls at unprecedented scales.

We continue to monitor and assess the risk for each of our properties analyzing hazard maps issued by local authorities, and by conducting due diligence review when considering investment.

Extreme Heatwaves

Heatwaves may occur in Japan during the summer season, which may potentially damage equipment/structure of our properties and endanger our tenants’ health conditions/living environment.

Some of our properties use effective heat insulation materials within the building’s roof and every floor’s ceiling and flooring, and we have been replacing old air conditioning units in the areas exclusively occupied by tenants.

Large-scale Earthquakes

Severe Human and Asset Damages Caused by Earthquakes

We are likely exposed to the risk of physical damage to our properties and damage to our tenants in the event of an unprecedented large earthquake.

As earthquakes happen frequently in Japan, we monitor the PML (Probable Maximum Loss) of every property and the portfolio as a whole, reported and updated by third-party experts, and we have earthquake and property insurance to hedge the risk.


When a large earthquake occurs, the Asset Manager will promptly implement disaster emergency and business continuity planning measures, collaborate with the property manager to confirm and keep the safety of the tenants (and their families) and provide them with necessary goods to sustain their lives.

Social Risks

Potential Changes in Business Environment Emerging Risks Our Understanding Potential Countermeasures
Declining Birthrate and Aging Population in Japan Declining Population of Young Adults (20s-30s)

As Japan’s birth rate has remained low in recent years, our key target population (young adults between 20s-30s) will decline to some extent and the demand for rental residences in the metropolitan area will decrease.

We continue to monitor the population inflow and outflow in the Tokyo metropolitan area and other relevant prefectures (using government data), to assess the supply-demand balance and develop proper leasing strategies. Because of Japan’s steadily aging population, we also own several senior operational residences to diversify our portfolio’s target age zones.

Potential Difficulty in Retaining Talented Employees at the Asset Manager and the Sponsor Group (Tokyu Land Corporation Holdings Group).

We may be exposed to the risk of deterioration of managerial and operational quality if the Asset Manager and/or the Sponsor Group are not able to retain sufficient numbers of talented employees.

The Asset Manager is committed to physical and mental health and well-being of each employee, promoting work-style reform and diversity. We have been and will contsfdinue to keep employees engaged and highly motivated, gain their loyalty by supporting acquisition of business knowledge, skills, qualifications and providing training, and promote career development through periodic performance evaluation/feedback.

Unpredictable Infectious Diseases Social and Economic Losses due to Potential Unpredictable Pandemic Diseases Our investment results may be impacted by social changes and/or economic declines, which may be caused by pandemic diseases.

We will maintain/improve our plans to minimize the potential impact of any future pandemic through various measures such as property sanitation and programs to raise tenant awareness.

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