BIRKILL Sustainability Policy

1. Purpose and Scope of this Policy - Birkill Developments (BD) aims to apply a best practice approach to sustainability across the organisation. This document sets out BD approach to incorporating responsible investing and sustainability as part of our business operations.

2. What is ESG? - Environmental Social and Governance (ESG) refers to the key factors when measuring the sustainability and ethical impact of an investment. BD defines Responsible Investing as an investment process that incorporates ESG factors into its day to day approach in addition to the normal financial criteria. Companies that invest in ESG programs have demonstrated that they can optimise operational performance, identify and mitigate risks and gain a competitive advantage in the industry.

Sustainable Development Goals

3. Defining our Focus - BD has identified the material ESG issues that are relevant to our business. This will help us to focus and act on the issues that are the highest priority for the business. These ESG areas focus on long term financial performance by investing in sustainable economies, assets and markets. Over the long-term, Sustainable Development Goals aim to achieve economic growth without compromising our environment or placing unfair burdens on societies.

4. Environmental, Social and Governance Commitments - BD believes that the sustainability of the business is intrinsically linked to the successful management of its financial, social and environmental risks and opportunities. BD is committed to sustainability and responsible investment through the following measures:
• identifying and understanding key ESG issues, such as climate change, within our business operations and investment decisions;
• considering ESG issues
in our operation and investment decision making;
• including ESG factors alongside financial analysis of assets;
• seeking appropriate disclosure on ESG issues by the entities in which we invest with the aim of improving their ESG related policies, practices and performance;
• actively engaging with likeminded investors in our quest to improve the environment and invest responsibly;
• supporting the development of
appropriate standards which improve sustainability and responsible investment;
• Committing to complying with applicable environmental law in our operations and minimising harm to the environment.

5. Climate Change - BD acknowledges that Climate Change poses a real and material risk to the property sector. With this in mind, we are committed to understanding our climate-related risks and opportunities and managing risks that are material to our business.

6. Implementation of this Policy - The implementation of this policy will be achieved by:
• Fostering an environmentally responsible culture within our workplace; and
• Regularly reviewing our Sustainability and Responsible Investment Policy to ensure it is aligned with best practice.

7. Governance - BD directors are committed to high standards of governance. The rights and interests of our business underpin our decision-making processes and are at the core of our corporate governance practices. BD corporate governance framework incorporates the requirements of market regulators, adopted codes and charters, documented policies and procedures and guidance from industry best practice. These policies and practices will remain under constant review as the corporate governance environment and good practice evolve.

8. Disclosure of this Policy - This policy will be published on BD Group’s website or other such pages as BD deems appropriate.