ESG Policy

At Martley Capital Group we recognise that ESG factors play a crucial role in the long-term success and sustainability of the real estate industry. As a pan-European real estate investment and asset manager targeting value-add equity and debt strategies, we are committed to integrating Environmental, Social and Governance (ESG) initiatives into our investment process and operating philosophy.

Martley Capital Group’s ESG Policy focuses on the following core principles:

Environmental Responsibility

We actively manage and seek to minimize the environmental impact of our investments by promoting sustainable practices, energy efficiencies, and resource conservation throughout the lifecycle of the properties we invest in and the buildings we work from. The risks and opportunities from climate and environmental change are at the forefront of Martley Capital Group’s ESG strategy and as such we actively seek every opportunity to reduce greenhouse gas emissions, improve energy performance, and adopt renewable energy solutions.

Social Impact

We are committed to promoting the well-being of the people who work for us, work with us and those who are impacted by our business. We prioritise the health, safety and well-being of our employees, occupiers, and stakeholders, ensuring strict adherence to applicable laws and regulations. In addition, we seek to actively engage with local communities, supporting initiatives that make a positive contribution to the people who live in them. At Martley Capital Group we promote an inclusive and diverse workplace and advance equity within the real estate investment industry to create equal opportunities for all.

Governance and Ethics

Integrity, accountability and transparency form the backbone of Martley Capital Group’s. Our governance framework ensures we comply with applicable laws, regulations and industry best practices. We advocate ethical conduct and anti-corruption measures throughout our organization and supply chains, conduct due diligence on our business partners and adhere to clear policies to prevent conflicts of interest. We will deliver continuous improvement by periodically reviewing and monitoring our ESG performance.

Reporting and Transparency

The use of systems to track and analyse the environmental performance of our assets is of paramount importance to our ESG strategy. We will use an environmental data management platform to identify and report environmental performance and risks. This allows us to establish effective business plans which will improve the sustainability performance of our assets and engage in environmental risk management. Monitoring performance allows us to share our data with occupiers, service providers and investors. We provide regular and transparent reporting on our ESG performance every quarter to keep our investors and stakeholders informed of the impact of our ESG strategy and progress we have made.

We pledge to adhere to internationally recognized reporting frameworks such as the Global Real Estate Sustainability Benchmark (“GRESB”) and the Principles for Responsible Investment (“PRI”) and to disclose relevant ESG metrics, achievements and future targets.

Roles and Responsibilities

All Martley Capital Group employees and relevant stakeholders have been provided with the necessary training to enable them to deliver their responsibilities against the requirements and commitments of Martley Capital Group’s ESG strategy. Below we set out which specific roles and responsibilities will be assumed by our employees and which teams will liaise to ensure they are carried out to the highest standards.

ESG Governance 

ESG matters are co-ordinated by Martley Capital Group’s ESG Manager and Head of the ESG Committee, who reports directly to the Senior Partners of the firm, the individuals accountable for achieving the commitments laid out on this Policy. The ESG Manager coordinates the work of the ESG Committee, which involves employee representation from all business areas and various levels of seniority.

ESG Committee

• Attend biannual ESG Committees to assess ESG strategy and effect continual improvement.
• Assess ongoing risk of investments in line with legislative developments, working with the Compliance and Legal teams as well as the 
Transactions team.
• Ensure sufficient resources and training are made available to successfully deliver commitments stated in ESG strategy.
• Liaise with the Investment Committee, providing relevant ESG information that will help inform investment decisions and flagging any notable ESG changes to the investment strategy process.

Transactions

• Complete and uphold pre-acquisition ESG Checklist considerations.
• Incorporate ESG strategy objectives within key stages of the acquisition process.
• Issue ESG Due Diligence Checklist to acquire key ESG data from the exiting building owner as part of handover and onboarding.
• Assess ongoing risk of investments.
• Carry out due diligence covenant screening of tenants.
• Ensure social aspects such as health, safety, tenant comfort, location and transport aspects of buildings are assessed.
• Conduct a review of the potential to improve the existing social or environmental performance as part of due diligence, including capital 
expenditure required.
• In addition to industry relevant standards and polices, ensure that all assets under management, potential investments, employees 
and stakeholders adhere to Martley Capital Group’s polices on anti-bribery and equal opportunities employment.

Asset Management

• Ensure energy, water and waste data is monitored through a data management system on a quarterly basis, and where relevant, establish fund level improvement programs.
• Incorporate ESG issues into asset business plans and ensure training needs are met for all employees and relevant stakeholders.
• Maintain active dialogue with key stakeholders on social issues and encourage building occupants to improve environmental performance.
• Lead and set ESG objectives for the Group’s Quarterly ESG Strategy Review.
• Ensure regular reviews of progress in meeting ESG objectives are held with Property Management teams, Asset Management teams and Investment Management teams.
• Assess tenant satisfaction with Property Management and wider ESG initiatives, where appropriate.
• Assist with ongoing environmental reviews and audits as part of due diligence.
• Ensure regular reviews of progress in meeting ESG objectives are held with property managers and the wider asset team.
• Ensure compliance with Minimum Energy Efficiency Standards (MEES) and maintain a good understanding of all current and future regulatory requirements.
• Where practical, track and assess the impact on energy efficiency of improvements made as part of refurbishments.
• Collate and report environmental performance data of landlord-controlled assets on a quarterly basis and request tenant-controlled environmental performance data annually.
• Periodically assess assets to seek reductions in overall energy and water consumption as well as waste production, while maintaining tenant 
comfort and needs.
• Proactively implement measures to improve ESG performance where appropriate and in line with legislative requirements.
• Monitor and ensure asset and unit-level site-based compliance is managed and valid documentary evidence is available for review/audit, as well 
as assisting as required.
• Ensure adherence to ESG-related contract requirements in Green Leases, as applicable.
• Adhere to Property Manager Standards of Sustainability, Development & Refurbishment Guides and communicate Tenant Sustainability Handbook 
and Sustainable Fit-Out Guide.

Compliance and Legal

• Review current and pending legislation and provide internal and, if appropriate, investor updates on ESG related trends.
• Attend twice yearly ESG Committee and ESG Working Party Group meetings.
• Keep the firm up to date and engaged with appropriate legislative measures across all regions.
• Incorporate ESG thematic research into mandate strategy and engage with the Investor Relations, Investment teams and Management teams to implement appropriate ESG measures where appropriate.
• Assess ongoing risk of investments in line with legislative developments, working with the Investment Management and Finance teams, as well as the Transactions team.

How We Champion ESG Internally  

In addition to our ESG strategy, Martley Capital Group follows an internal policy to promote and positively manage environmental and social issues in our offices in the UK and Europe which include, but are not limited to:

• The provision of employee wellbeing and mental health programmes, including subscription services to mental health services.
• A leadership team dedicated to promoting diversity, equality, and inclusion.
• A corporate governance policy which protects workers’ rights, ensures equal opportunities for all, and seeks to eliminate forced labour and fraudulent activity.
• Waste office management initiatives which aim to minimise office waste and maximising reuse or recycling of materials and redundant equipment, as well as identifying opportunities to promote effective waste management across our estates.
• Reducing energy consumption by purchasing energy efficient equipment and maintaining good operational standards.
• Encouraging walking, cycling and/or using public transport to attend meetings and site visits, as well as avoiding physically travelling to meetings where alternatives are available and practical.
• Promoting the use of public transport by locating offices in accessible locations.