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ESG Policy Statement

Introduction

Wellbeing Places REIG Limited ("the company") recognises that responsible investment and sustainable business practices are fundamental to long-term value creation in the real estate sector. As a real estate investment group operating in the United Kingdom, we are committed to integrating Environmental, Social and Governance (ESG) considerations into our investment strategy, asset management activities and organisational culture.

The built environment plays a significant role in shaping environmental outcomes, economic development and community wellbeing. Through our investment decisions and management of real estate assets, we seek to minimise environmental impact, contribute positively to the communities in which we operate, and maintain high standards of corporate governance.

This ESG Policy outlines our approach to responsible investment and establishes the principles that guide our activities across the investment lifecycle.

Scope

This policy applies to:

  • All real estate investments managed or owned by WBP REIG
  • Asset management and development activities
  • Employees, directors and contractors
  • Key suppliers and property managers acting on behalf of the firm

Regulatory Context

The UK real estate sector operates within an evolving regulatory landscape that increasingly emphasises environmental performance, climate risk disclosure and responsible governance. WBP REIG seeks to remain informed of relevant legal and regulatory requirements and to incorporate them into our investment and operational practices where applicable.

Relevant areas of regulation and guidance may include:

  • UK climate-related financial disclosure requirements aligned with TCFD principles
  • Minimum Energy Efficiency Standards (MEES) affecting property Energy Performance Certificates (EPCs)
  • Environmental and building regulations affecting property development and refurbishment
  • Corporate governance and sustainability disclosure guidance issued by the Financial Conduct Authority

Where appropriate, we aim to align our internal processes and reporting with these regulatory expectations and broader market best practices.

Environmental Responsibility

The environmental performance of buildings is a key consideration in the management of real estate assets. We recognise that properties contribute to energy consumption, carbon emissions and resource use, and we therefore seek to manage environmental impacts responsibly while supporting the long-term sustainability of our portfolio.

Environmental considerations are incorporated into investment decision-making, asset management and development activities. During the acquisition process, we seek to identify environmental risks, regulatory compliance requirements and potential opportunities to improve sustainability performance.

Where feasible and commercially appropriate, we seek to enhance the environmental performance of our properties through measures such as:

  • improving building energy efficiency and operational performance
  • considering environmental risks and climate resilience during investment analysis
  • supporting responsible water use and waste management practices
  • incorporating sustainable design principles in development and refurbishment projects

We also monitor regulatory developments related to energy performance and carbon reduction to ensure that our portfolio remains aligned with evolving environmental standards.

Social Responsibility

Real estate investments influence the wellbeing of tenants, employees and the communities in which properties are located. We therefore aim to manage our assets in a way that promotes safety, accessibility and positive social outcomes.

We are committed to maintaining safe and well-managed buildings and to ensuring that appropriate health and safety standards are upheld across our operations and supply chains.

Our approach to social responsibility includes:

  • maintaining high standards of tenant safety and building compliance
  • promoting accessibility and inclusive environments within our properties
  • engaging responsibly with property managers, tenants and service providers
  • encouraging fair and responsible practices across our supply chain
  • supporting diversity, equality and professional development within our organisation

By maintaining these principles, we aim to ensure our investments contribute positively to the communities in which we operate.

Governance

Strong governance structures are fundamental to responsible investment and effective risk management. WBP REIG is committed to maintaining high standards of integrity, transparency and accountability in all aspects of its operations.

The firm maintains internal policies and controls designed to support ethical conduct, regulatory compliance and responsible decision-making. ESG considerations are integrated into the firm's broader risk management and governance framework.

Key governance principles include:

  • adherence to applicable laws and regulatory requirements
  • maintaining policies addressing conflicts of interest and ethical conduct
  • implementing appropriate anti-bribery and corruption controls
  • ensuring that ESG considerations are reviewed as part of investment decision-making

Oversight of ESG matters rests with senior management, who are responsible for ensuring that this policy is implemented across the firm's investment activities.

ESG Integration in the Investment Lifecycle

ESG factors are considered throughout the lifecycle of real estate investments.

During the acquisition stage, ESG-related risks and opportunities are assessed as part of the due diligence process. This may include reviewing environmental performance, regulatory compliance, building condition and potential sustainability improvements.

During asset management, we seek to identify opportunities to enhance operational efficiency and environmental performance where appropriate. This may involve working with property managers and tenants to support responsible operational practices.

For development and refurbishment activities, we seek to incorporate sustainable design principles and responsible construction practices where commercially viable.

Monitoring and Reporting

WBP REIG recognises the importance of monitoring ESG performance and maintaining transparency with stakeholders. Where appropriate, we seek to track relevant indicators relating to environmental performance, regulatory compliance and operational sustainability across our portfolio.

We may report ESG-related information to investors in line with applicable regulatory expectations and recognised disclosure frameworks, including climate-related reporting aligned with the Task Force on Climate-related Financial Disclosures where relevant.

Continuous Improvement

ESG standards and regulatory expectations continue to evolve within the UK real estate sector. WBP REIG is committed to reviewing and enhancing its ESG practices over time to reflect changes in regulation, industry best practice and investor expectations.

We recognise that responsible investment requires ongoing evaluation and improvement, and we will continue to refine our approach as our portfolio and organisational capabilities develop.