Environmental, Social & Governance (ESG) Principles

Firm Summary

Founded in 2003, Westhome is a premier real estate investment, management and development firm dedicated to redefining urban living. Focused on multifamily and mixed-use projects in high-growth markets in the Western United States, Westhome connects the comforts of home with the energy of city life. At Westhome, we are driven to make intentional and considered choices when it comes to investing: (i) selecting dynamic neighborhoods in urban-infill markets in the Western United States, (ii) incorporating our buildings into the local communities and (iii) designing homes that enable people to live beyond their walls. Westhome recognizes that its employees, partners and projects can have an impact on the environment and community, and we believe we can generate attractive investment returns while also providing sustainable benefits to society.

Westhome strives to integrate ESG factors into the investment process and ongoing operations of our assets in order to (i) mitigate investment risk and, where possible, enhance investment returns, and (ii) ensure that the assets in which we invest on behalf of our clients and our tenants respect and, where possible, benefit society and the environment.

Our ESG policy is further informed by our five Core Values, which guide all of Westhome’s decision-making:

• Impactful: We turn cities into communities, people into neighbors and houses into homes.
• Purposeful: We achieve our highest outcomes through meaningful, considered and reasoned thinking.
• Straightforward: Open, honest and upfront conversations lead to the best results.
• Bold: Be bold. Deliver beyond expectations.
• Agile: We continually reevaluate and adapt to the changing environment without losing momentum or vision.

Environmental Advancement

Westhome invests exclusively within multifamily and mixed-use real estate. We strive to develop, acquire and operate responsibly by limiting the impact we have on the natural landscape, minimizing our carbon footprint, maximizing efficiencies, and reducing resource use and waste. This applies equally to our ground-up development, value-add acquisitions, asset and property management, and in the operation of our corporate headquarters.

• To help achieve our environmental objectives, we:
  Design all of our new developments to a LEED silver minimum equivalency, incorporating an integrative process, location and transportation considerations, sustainable sites criteria, energy and water efficiency, materials and resources considerations and indoor environmental quality.
• Comply with all local Green Building and Title 24 code requirements to meet and exceed minimum green building standards and embrace renewable energy technologies such as solar thermal and solar PV systems
• Consider biodiversity and local habitat when conducting landscaping and development activities.
• Work to understand business risks relating to climate change and opportunities to support the transition to a low-carbon economy and enhance resilience in our portfolio.
• Construct, renovate and operate our assets and corporate headquarters with features designed to reduce energy and water consumption, such as energy efficient appliances and fixtures, ambient light and motion sensors, storm water capture and reuse, low flow plumbing fixtures and water filtration systems
• Establish waste management programs focused on creating a culture of conservationism and recycling for our residents and our employees
• Utilize electronic and digital communication and documentation services to reduce paper usage in our property management and corporate operations and limit and/or eliminate single use products in our corporate office

Social Responsibility

At Westhome, we seek to enhance lives within our physical footprint and beyond, designing spaces and communities that will positively impact neighborhoods and investing in our employees as stewards of our vision.

For our residents and the communities they inhabit, we:

• Design buildings with open spaces and include inspiring art installations to enhance the beauty of the neighborhood
• Commit to engaging locally-based contractors and other third-party service providers who pay a fair wage and a fair benefit to their employees, consistent with our Responsible Contractor Policy
• Promote overall health and wellness of tenant, contractors, employees and larger community through design, development and operations of buildings and communities
• Host resident events centered on local charities and conservation efforts
• From the top down, live out our beliefs in ESG through civic engagement, charitable investments, volunteerism and partnerships with community organizations.

For our employees, we:

• Are an equal opportunity employer focused on recruiting, retaining and developing a diverse employee base and management team
• Take care of our employees with competitive pay and benefits, flexible spending accounts, parental leave and retirement savings plans
• Prioritize a corporate headquarters that includes spaces to collaborate and de-stress, and provide ergonomic offices and desk spaces to ensure health and well-being while at work
• Arrange detailed onboarding plans to ensure new employees are set up for success and nurture our talent with management and other training programs
• Garner anonymous employee feedback through annual surveys to inform our programs and communications plans

Ethical Governance

We believe robust governance, alongside our diverse and experienced management team with a history of success, will lead to optimal outcomes over the long term.

As a fiduciary to our advisory clients and a Registered Investment Advisor with the U.S. Securities and Exchange Commission (“SEC”), Westhome has a duty of loyalty and a duty to always act in good faith, to place our clients’ interests first and foremost and to make full and fair disclosure of all material facts.

Critical components of our governance policy include:

• Our compliance manual addressing, among other things, conflicts of interest, anti-money laundering, political contributions, cybersecurity/data protection, gifts, social networking, business continuity and our complaint policy
• Administration of our SEC compliance program by our Chief Compliance Officer, with assistance from our in-house legal team and a third-party compliance consultant
• Compliance training for all employees at the outset and regularly throughout their tenure at Westhome
• Employee compensation, including executive compensation, decisions determined with board oversight
• Quarterly and annual reporting consistent with our Valuation Policy, with annual audits performed by independent and reputable auditors registered with and subject to regular inspection by the Public Company Accounting Oversight Board

Investment Management Guidelines

Westhome believes that the key to generating consistent, long-term returns depends on its ability to identify and target projects that will drive meaningful improvements in society and manage those investments with consideration for ESG factors throughout the investment. When analyzing potential investment opportunities during the due diligence stage, Westhome regards each of the factors below as key diligence items in relation to the firm’s ESG guidelines:

• Proximity to transit
• Affordability components
• Job creation
• Environmental impacts of the development and opportunities for water and energy reduction, urban infill and environmental remediation (including USTs and soil for new development and lead-based paint and asbestos for value-add renovations)
• Opportunities to reuse building materials, provide open space and habitability, and include art components within the design
• Opportunities at value-add properties to extend the useful life of the building and improve the tenant experience by completing much needed deferred maintenance

When selecting and appointing third-party property management companies, we seek to evaluate ESG capabilities, integrate requirements into agreements and communicate our ESG values and commitments. When managing operating properties, we monitor relevant environmental and social performance indicators and track our performance over time. Our ESG Taskforce oversees implementation of our ESG Policy and includes representations from across the business. The ESG Taskforce is responsible for communicating our ESG Policy to all employees.

Annual ESG Review

On an annual basis, Westhome’s ESG Taskforce will assess our performance under this policy by gathering and reviewing data related to these objectives to further understand the collective impact of our portfolio on society and the environment, assess the overall ESG maturity of our investments and identify priority areas for engagement in the coming year.