EU Sustainable Finance Disclosure Regulation

This page contains certain disclosures required to be made pursuant to Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability‐related disclosures in the financial services sector (“SFDR“).

SFDR Entity-level Disclosures

Sustainability Risk Policies – Article 3 Disclosure

The following disclosure is being made in accordance with Articles 3(1) and (2) of the SFDR.

This disclosure applies to the following entities:

• CBRE Investment Management EMEA AIFM B.V.
• CBRE Investment Management Luxembourg AIFM S.à r.l.
• CBRE Investment Management (UK Funds) Limited
• CBRE Investment Management Indirect Limited

Together the CBRE IM Entities.

The CBRE IM Entities are "financial market participants" and, in some cases, also "financial advisers" for the purposes of SFDR.

A sustainability risk is defined under SFDR as an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of an investment.

The CBRE IM Entities consider that sustainability risks can have a material impact on investment performance and, therefore, consideration of sustainability risk is integral to the CBRE IM Entities’ investment decision-making, investment management and investment advisory process.

The Firm’s President and Co-CEO has the ultimate oversight and responsibility for sustainability, including the CBRE IM Global Sustainability Policy and Vision. The President meets with the Head of Sustainability and Innovation on a regular basis and consults with various Executive Committee (EXCO) members on sustainability topics as needed.

The Global Sustainability Council is a business-wide committee that provides strategic direction and strives to integrate sustainability principles into aspects of business and investment processes, where consistent with investment objectives. The Council is comprised of senior leadership team members, covering the four active investment strategies and various corporate functions.

The CBRE IM Entities' policies on the integration of sustainability risks into their investment decision-making, investment management and investment advisory processes, as relevant, are incorporated into specific procedures across the business.

Where a CBRE IM Entity is providing portfolio management or investment advice, client sustainability preferences are determined in conjunction with suitability assessments.

Strategic risk framework: The Framework defines the process through which risks can be assessed, monitored, reported and mitigated in a consistent manner; including any necessary investment constraints and restrictions.

House views: Portfolio construction is driven by a top-down house view pursuant to current cycle positioning and is generally reviewed and revised on a semi-annual basis. The Firm’s Insights & Intelligence Team (Research Team) undertakes both bottom-up and top-down research to identify investment risks and opportunities, including those related to sustainability and broad megatrends. They monitor these trends and incorporate relevant insights into market selection.

Investment strategy: Portfolio-level investment strategy and asset plans are prepared, adopted and updated for each mandate, as applicable, which set out the key objectives for a portfolio in the forthcoming year. Portfolio composition, past performance, revised forecasts using the latest market forecasts and the most current tactical recommendations will influence decisions. Sustainability leads are appointed to coordinate the implementation of the investment strategy.

Investment decision: The Firm’s selection process is structured to include a review and approval of prospective investments. The Investment Committees are responsible for the governance of our acquisitions process, with the overriding objective of delivering each mandate’s target return within a pre-defined strategic risk framework. A senior Sustainability Team member is on all private market Investment Committees. Investment Committee memoranda contain a section on sustainability and climate change risk, which is part of the investment due diligence analysis and incorporated into underwriting, investment positioning and the investment plan when applicable for the purposes of risk mitigation and value creation.¹

During pre-due diligence, the proposed transaction will be evaluated from a sustainability perspective to identify potential sustainability-related risks, opportunities and ensure sufficient budget is allocated for any in-depth assessments. The risk levels are determined using physical and transition climate risk tools, portfolio level sustainability targets (when applicable) and external benchmarks and regulations according to location, asset type and other relevant metrics.

The due diligence process further examines any items flagged in the pre-due diligence process, which are addressed by the transactions team, supported by external sustainability specialist consultants, data providers and the Sustainability Team, as applicable. The findings are then used to help ensure adequate provision is made in the financial underwriting, including investment business plans.

Operator strategy: Following acquisition, the asset or investment is transitioned to the appropriate investment management team. A sustainability action plan is generally developed for individual directly managed investments that we control in commingled funds and separate accounts, as appropriate for the asset type and investment strategy.

For indirect private real estate, private infrastructure and listed real assets strategies, engagement with investee companies, managers and funds is important to our sustainability efforts. CBRE Investment Management partners with these stakeholders seeking to positively influence the management of sustainability risks. The purpose of sustainability engagement is to identify risks and opportunities, help ensure risk management and continued performance improvement and promote positive action.

Execution and performance reporting: CBRE Investment Management seeks to undertake detailed sustainability performance measurement, monitoring and reporting as appropriate for each mandate and investment strategy. Where possible, accredited third-party systems are used to assess, certify and benchmark the sustainability performance of assets under management, such as PRI, GRESB Infrastructure and Real Estate, BREEAM and LEED.

Principal Adverse Impact Statements – Article 4 Disclosures in respect of:

2024 CBRE Investment Management EMEA AIFM B.V

2024 CBRE Investment Management Luxembourg AIFM S.à r.l.

2024 CBRE Investment Management (UK Funds) Limited

(each a “Company” and collectively the “Companies”) 

1. Statement
   The Company intends to comply with Article 4 of the SFDR and considers the principal adverse impacts of its investment decisions on sustainability factors. This statement is the principal adverse sustainability impact statement of the Company.

2. Definitions
   Sustainability factors: Environmental, social and employee matters, respect for human rights, anti-corruption and anti-bribery matters, as defined in Article 2 (24) of SFDR.

   Principal adverse impacts: This is understood to refer to the negative impact an investment has on sustainability factors.

3. Overview
   CBRE Investment Management (of which the Company is a part of) (the Firm) seeks to be a global leader in the real assets investment management industry by offering a broad and deep investment platform that consistently delivers world class investment results and exceptional client service. Leadership in, and implementation of, sustainability practices is therefore a fundamental part of the Company's global business strategy.

   The Firm believes that sustainability factors are fundamental to our business and to driving long-term out performance. The Firm's Sustainability Vision has ambitious goals for the next two decades, including a corporate commitment to achieve many of our stainability aspirations by 2050. Distilled from a materiality assessment, these commitments span across three distinct focus areas: climate, people and influence.

   Climate: Future-proof our investments by focusing on climate mitigation and adaptation.

   People: Champion our RISE values (respect, integrity, service and excellence), which underpin everything we do.

   Influence: Engage and positively influence key stakeholders where the Firm does not have direct management control.

   Once an asset is purchased and transitioned into a portfolio managed by the Company for and on behalf of any of the funds it manages (a Fund), each relevant Fund's investment team seeks to implement the Firm's internal data management system, which, in turn, allows the Company to measure, manage and improve energy and sustainability performance. This system facilitates the collection of energy, water, waste, audits, projects (including stakeholder engagement), certifications and ratings. Each relevant Fund's investment team generally utilizes the collected data to analyze sustainability key performance indicators, file for certain ratings, assist with building certifications and determine other appropriate green building practices and initiatives. On an annual basis, the majority of Funds contribute to GRESB, a global benchmark for real estate and infrastructure, review their benchmark score and set sustainability goals for the following year.

   Funds typically report on sustainability issues in their periodic reports, at advisory board meetings and in ad hoc communications to their respective investors.

   The Company has a comprehensive list of sustainability-related data that we seek to collect during the transaction due diligence process. The output enables the Company to assess the potential exposure to sustainability risks which allows each relevant investment committee to evaluate whether such risks have been adequately addressed and mitigated by the Company.

   The Firm integrates sustainability in the asset management process within a Fund's portfolio to identify any assets that may need a more detailed site audit or decarbonization audit.

4. Description of the principal adverse impacts on sustainability factors
   The principal adverse impact indicators currently monitored and evaluated include:

   
   

   No.	Indicator	Summary/Metric	Data source(s)
   17 (Table 1)	Fossil fuels (Mandatory)	Exposure to fossil fuels through real estate assets Share of investments in real estate assets involved in the extraction, storage, transport or manufacture of fossil fuels	1. Asset type list from internal database 2. Tenant list for assets from internal database
   18 (Table 1)	Energy efficiency (Mandatory)	Exposure to energy-inefficient real estate assets Share of investments in energy-inefficient real estate assets	1. EPC ratings obtained by property managers and put into the Company's internal data management system, which is used as part of the Company's GRESB submission 2. Energy intensities calculated via absolute energy use and floor area data via the Company's internal data management system, which is used as part of the Company's GRESB submission
   18 (Table 2)	Greenhouse gas emissions (Additional)	Scope 1 GHG emissions generated by real estate assets Scope 2 GHG emissions generated by real estate assets Scope 3 GHG emissions generated by real estate assets Total GHG emissions generated by real estate assets	1. GHG emission factors publicly available and purchased (e.g., IEA) to calculate emissions from energy use 2. Renewable energy use via the Company's internal data management system and used for GRESB submission 3. Fuel, district and electricity data for landlord and tenant-controlled areas via the Company's internal data management system and used as part of the Company's GRESB submission
   19 (Table 2)	Energy Consumption (Additional)	Energy consumption in GWh of owned real estate assets per square meter	1. Energy intensities calculated via absolute energy use and floor area data from the Company's internal data management system and used as part of the Company's GRESB submission




5. Description of policies to identify and prioritize principal adverse impacts on sustainability factors
   During due diligence, the Company identifies the potential for improvements that would lessen a property's environmental impact and promote wellbeing. The Company typically retains third-party specialist consultants to evaluate physical and locational characteristics of each investment. The relevant investment team then identifies risks and opportunities that can be addressed through physical upgrades and process improvements for potential investments which the Company seeks to include in each asset's investment strategy and capital expenditure program. This is done systematically with oversight from the Sustainability Team through representation on Investment Committees to ensure consistency across investments. The methodology may consider sustainability factors such as:

   • Location
   • Tenant and industry exposure
   • Energy efficiency
   • Energy labels
   • The potential for green building certification
   • The presence of harmful materials or contamination
   • A building's exterior environmental characteristics (orientation, facades, landscape, etc.)
   • A building's interior environmental/wellbeing characteristics (lighting, air quality, tenant comfort, etc.)
   • Climate change risks and opportunities
   • Access to public transportation, employment and amenities

   The output of the process assesses the potential exposure to sustainability risks. The information is typically presented to each relevant Fund's investment committee with the aim of helping them evaluate whether such risks have been adequately addressed and mitigated and ensures a consistent global approach.

   During the Company's asset management process, for transition risks associated with climate change, the Company utilizes a third-party vendor to identify any potential stranding or obsolescence risk. The Company seeks to integrate climate and other sustainability risks into the financial modelling for any new acquisition as part of the calculation of a risk-adjusted return. For the assessment of physical risks (river flood, surface flood, coastal flood, wildfire, storms, tropical cyclones, subsidence, landslide, extreme heat days, drought and storm surge), the Company typically utilizes another third-party vendor to provide a high-level indication of the risk exposure for any location globally. Should a property be found to have the potential of being at high or critical risk, the Company generally undertakes further investigations into the building and the location.

6. Engagement
   The Company regularly engages with property managers, leasing teams and tenants to share best practices, conduct tenant engagement surveys and provide training and programming-including sustainability issues and expectations. Many of the property managers are trained on the use of the Company's internal data management system and on the sustainability data they are required to collect and input.

   Tenants have a key role to play as users of the properties in which each Fund invests. The Company actively seeks to engage with tenants to help achieve the Firm's key stewardship objectives. Tenant engagement activity may include initiatives such as tenant and resident satisfaction surveys, tenant data collection and green leases. Although priorities may differ by geographical location, the Firm seeks to maintain consistent reference to our sustainability vision to guide engagement across our global platform.

7. Reference to responsible codes and international standards
   The Firm has been a signatory to the Principles for Responsible Investment (PRI) since 2009, participated in the GRESB pilot in 2009 and has actively contributed to GRESB since. The Firm developed our first Sustainability Policy in 2013 and supports the Global Compact Principles and United Nations Sustainable Development Goals (SDGs). The Firm seeks to continually evolve our sustainability practices as new technologies are developed and new processes established to improve efficiencies and effectiveness. On an annual basis, or as needed, the Firm reviews and revises our Sustainability Policy. The Firm is a member and active participant in PRI and the Institutional Investors Group on Climate Change (IIGCC) as well as a supporter of the Task Force on Climate related Financial Disclosures, which has now been subsumed by the International Financial Reporting Standards (IFRS) Foundation's International Sustainability Standards Board (ISSB).

   The Firm is also a signatory, member or participant in a number of other global and regional sustainability-related networks and initiatives, including: Better Buildings Partnership,, Global Investor Coalition on Climate Change (including AIGCC, Ceres, IGCC, IIGCC), Institute of Corporate Responsibility and Sustainability, Institution of Environmental Sciences, Pensions For Purpose, Sustainability Accounting Standards Board, Sustainability Policy Advisory Committee of the Real Estate Roundtable, The Aldersgate Group, The Association of Real Estate Funds ESG and Impact Investing Committee, The European Association for Investors in Non-Listed Real Estate Vehicles (INREV), UK Green Building Council, and the Urban Land Institute. Involvement in these organizations reinforces the Firm's commitment to sustainable business practices.

   Principal Adverse Impact Statement-Article 4 Disclosure with respect to CBRE Investment Management Indirect Limited

   CBRE Investment Management Indirect Limited (CBRE IM Indirect) recognizes the importance of the consideration of the principal adverse impacts of its investment decisions on sustainability factors.

   However, CBRE IM Indirect has elected that for purposes of (and in accordance with) SFDR, it will not seek to consider principal adverse impacts of investment decisions on sustainability factors, as prescribed by SFDR, given that the applicability of company-specific indicators to private indirect real estate investments is unclear. For this reason, the scope of principal and additional adverse sustainability impacts to be considered for such investments is not fully understood and compliance cannot be confirmed at this time.

   CBRE IM Indirect will reassess this decision once clarity on the applicability of company-specific vs. real estate­ specific indicators to private real-estate investments is available.

   Notwithstanding this decision, CBRE IM Indirect confirms that as a more general matter, sustainability considerations remain of great importance, including in the context of investment decisions.

Remuneration Statement – Article 5 Disclosure

Disclosure pursuant to Article 5 of SFDR.

CBRE Investment Management has established remuneration policies (collectively, the “Policy”) applicable to all group entities (together,  “CBRE Investment Management EMEA” or the “Company”) established in Europe, the Middle East and Africa (“EMEA”). The Policy is developed, approved, implemented and monitored by a series of bodies within the group structure, including in particular the boards of the entities in scope and relevant human resources and risk management departments. The Policy applies to all employees of CBRE Investment Management EMEA, save for limited exceptions.

The Policy has been developed with the aim of supporting the Company's business strategy, corporate values and long-term interests, including by facilitating the identification, assessment and management of sustainability risks when determining individual remuneration packages. The key principles of the Policy include fostering appropriate risk culture (including with respect to the management of actual and potential conflicts of interest) and compliance with applicable law and regulation.

The performance management and rewards framework envisioned by the Policy has been designed to promote effective risk management, including with regards to sustainability risk.

SFDR Product-level Disclosures

This disclosure applies to the following entities:

• CBRE Investment Management EMEA AIFM B.V.
• CBRE Investment Management Luxembourg AIFM S.à r.l.
• CBRE Investment Management (UK Funds) Limited
  (each such entity being a “Manager”)

The Manager manages (i) certain products which promote environmental and/or social characteristics and fall under Article 8(1) of SFDR; and (ii) certain products which have sustainable investment as their objective and fall under Article 9(1) of SFDR.  The disclosures required under Article 10(1) of SFDR and other information on sustainability-related matters in respect of such products can be found at the link immediately below. The Manager has taken measures to protect the confidentiality of the information contained in such disclosures.

SFDR Article 10 Disclosures

CBRE Global Infrastructure Fund ("CGIF")