INTERCONTINENTAL’S ENVIRONMENTAL, SOCIAL, AND GOVERNANCE POLICY
Intercontinental Real Estate Corporation, together with its affiliated companies (“Intercontinental”), invests in, develops, owns, and operates commercial real estate properties throughout the United States. Intercontinental property types include office, multifamily, industrial, retail, healthcare, hotel and senior living, in aggregate comprising more than $10B in market value and 29 million square feet across 25 states.We are proud of Intercontinental’s history in the real estate industry, dating back to 1959, and of its track record of using domain experience and knowledge to seek to create value for investors. Our primary objective is to maximize the financial return of Intercontinental investors. We believe that environmental, social, and corporate governance (“ESG”) issues may affect the performance of our investments. We strive to adhere to high ESG standards that we integrate fully into Intercontinental’s business strategy.
Intercontinental recognizes that its company, together with the real estate properties it owns and operates, impact the environment. Intercontinental is committed, to the extent possible, to developing processes that track and review the environmental impact of these operations. Intercontinental is also committed to encouraging its stakeholders (including tenants) to align with its ESG objectives to enhance the sustainability of these operations. In 2020, Intercontinental initiated a program to measure the consumption of energy and water, generation of waste, and emission of Greenhouse Gas (GHG), with an initial emphasis on maximizing data coverage within its portfolio of real estate holdings. After establishing a performance baseline, Intercontinental is committed to setting goals in the future to reduce usage of energy and water, generation of waste, and emission of GHG.
Intercontinental is committed to being an equal employment opportunity employer, guided by capabilities and qualifications without discrimination against any employee or applicant related to race, color, religion, creed, sex, pregnancy, sexual orientation, gender identity and gender expression, transgender status, national origin, age, physical or mental disability, gender information or any other characteristic protected by law. Intercontinental’s Employee Handbook elaborates its values and ethics, together with its goal of creating a respectful workplace. Intercontinental implements and provides training on its policies relating to discrimination and harassment, complaint procedures, and no retaliation. Intercontinental does not tolerate child labor, forced or compulsory labor, or human rights violations. Intercontinental has established and maintains a Responsible Contractor Policy to support fair wages and safe work environments. Intercontinental is committed to following labor standards that meet or exceed those of the International Labour Organization (ILO). In 2020, Intercontinental established a Diversity and Inclusion Council, with members from all parts of the company, and performed a corporate climate survey. Intercontinental is committed to establishing a diversity and inclusion strategy and related objectives. Intercontinental may view certain key stakeholders, for examples its investors, tenants, employees, and partners, as “customers,” and therefore seek to understand their satisfaction and feedback through various means. Finally, Intercontinental strives to have positive impact on communities, including ones important to its stakeholders and those where its buildings are located, through charitable and other contributions.
Intercontinental’s Executive Committee, led by the CEO, oversees its ESG strategy. In 2020, Intercontinental established an ESG committee to: formulate and implement ESG strategy; monitor ESG opportunities and risks, including transition risks; review and process ESG-related controversies, misconduct, penalties, incidents, accidents, and breaches against its ESG policy; and report periodically to the Executive Committee. Beginning in 2020, all Intercontinental employees included ESG goals in the process by which they and their managers review performance and establish annual goals. This performance review process applies to all Intercontinental employees, including the executive team, and has both financial and non-financial consequences.
An SEC registrant since 1999, Intercontinental maintains a strong compliance environment, including processes to receive, process, and report complaints. Intercontinental’s high governance standards are reflected in the Employee Handbook, Code of Ethics, and Compliance Manual. These foundational documents are reviewed and updated as needed, at least annually, by Intercontinental’s Chief Compliance Officer and approved by its Executive Committee. Together the documents provide employees with policies in critical areas such as non-discrimination, anti-harassment, anti-corruption, anti-money laundering, conflicts of interest, political contributions and cybersecurity. Additionally, Intercontinental provides regular, on-going training to all employees in these areas. Finally, Intercontinental’s governance is supported through executive committee, investment committee, and advisory board structures.
Intercontinental is committed to engagement of its stakeholders on ESG topics through communication and nurturing of ongoing partnerships and relationships. Key Intercontinental stakeholders include employees, investors, joint-venture partners, property managers, vendors, and tenants. Intercontinental has undertaken engagement through investor communications, employee surveys, annual meetings for investors and key partners, education and training of employees and critical service providers (e.g. training for attorneys on green leasing), and by making charitable contributions to communities important to various stakeholders (as highlighted on the company website). Intercontinental monitors and reviews ESG practices and policies of its third-party property managers, and may train them as needed on using Energy Star and other tools to document energy, water, and waste data for Intercontinental properties. In 2020, Intercontinental initiated a vendor management program, including an objective to incorporate ESG-related diligence and evaluation of suppliers of critical enterprise services and of joint-venture partners.
Heath and Wellbeing
Intercontinental is committed to maintaining a safe and healthy work environment and eliminating known safety and other health hazards. This commitment is stated and further explained in Intercontinental’s Employee Handbook, which all employees must read and certify annually. The handbook contains many sections relevant to employee health and well-being, including: creating a respectful workplace, anti-discrimination policy; complaint procedure; no retaliation policy; open door policy; no-smoking and drug policies; and policies relating to security and workplace violence. Intercontinental provides training relating to these policies and strives to implement them rigorously. Intercontinental invests significant resources in quality security systems to protect employees when at work. Intercontinental provides competitive health, dental, vision, disability, and medical and parental leave benefits to employees. Intercontinental provides flu vaccination, CPR training, and maintains an automatic cardioverter defibrillator at its company headquarters. Intercontinental provides fitness classes to employees both online and at the state-of-the-art gym facility it maintains at Boston headquarters.
Intercontinental is committed to practices which promote health and well-being of the tenants and visitors of building spaces it controls. For example, Intercontinental may influence building security systems, common space security, amenity spaces such as gyms, indoor air quality, smoking policy, pandemic related safety protocols, and other aspects of the commercial real estate buildings it owns. Values emphasizing the health and safety of workers and construction sites are implicit in Intercontinental’s Responsible Contractor Policy
Greenhouse Gas (GHG) Emissions Management and Climate Change Adaptation
Intercontinental is committed to reducing GHG emissions at the corporate level and at the level of the real estate buildings it owns and operates. In 2020, Intercontinental initiated a program to benchmark and track GHG emissions using utility data for energy consumption or management of energy from renewable and non-renewable sources. Intercontinental is striving to maximize available data coverage of buildings in its portfolio, either as allowed contractually or by seeking permission from tenants, and to understand how it is capable of reducing GHG emissions through its own actions or by attempting to influence tenant practices. In future years, Intercontinental intends to set targets to reduce energy, water, and waste in order to reduce GHG emissions. Intercontinental is also evaluating how to prepare further for long-term change in climate conditions and climate related events.
Intercontinental recognizes, monitors, and attempts to mitigate the impact of various types of short-term shocks and long-term stressors on its enterprise and real estate holdings. Intercontinental maintains, frequently tests, and documents its business continuity program and procedures designed to enable the company to protect employees and continue to perform all critical business functions in scenarios involving disasters, catastrophes, pandemics and other emergency events occurring at one or all of its office locations. Intercontinental invests extensively in information-technology systems which provide redundancy at disaster recovery locations and enable employees to perform their jobs remotely.
Intercontinental recognizes scientific evidence that climate change due to GHGs is contributing to rising sea levels, coastal flooding, wild fires, and extreme weather events, among other phenomena which threaten its real estate holdings. The inevitable transition to a low-carbon economy creates risks and opportunities that Intercontinental strives to assess systematically, monitor, and manage. For example, a key material risk from the transition to a low-carbon economy stems from the potential challenges and costs of adapting to policy changes designed to decrease carbon emissions of commercial real estate buildings. Such policy changes may be implemented through regulation, law, and taxation at the federal, state, and city levels. Additional risks derive from the impact of the transition on economic activity of the cities where real estate holdings are located, and on the underlying businesses of tenants who lease space at these real estate holdings. The ESG Committee strives to monitor emerging climate-change policy, and report periodically to the Executive Committee on important developments and their potential impact on Intercontinental’s business. Intercontinental’s Portfolio Management, Acquisitions, and Asset Management groups evaluate these and other transition risks, together with many other variables, when underwriting geographical allocations, property-type allocations, and individual tenant creditworthiness.
Climate change, natural disasters, social unrest, and other catastrophic events pose material, climate-related physical risks to Intercontinental real estate holdings. Intercontinental’s Acquisitions and Asset Management groups evaluate potential physical risks to real estate holdings, often in conjunction with third-party experts, in order to: ensure that buildings are constructed and maintained to withstand significant stress from events most likely to pose a threat to the relevant location; acquire and maintain insurance at prudent levels to mitigate economic losses due to physical damage. The Acquisitions and Asset Management groups may create or commission expert documents and analysis, as needed, as part of their processes to evaluate such risks and manage related insurance coverage, and present this material to the Investment Committee and/or Executive Committee. Asset management creates a budget for each Intercontinental real-estate building annually, and includes line items if needed to pay insurance premiums and make capital expenditures which may impact sustainability. Intercontinental works with a third-party service provider and uses its software to monitor physical risk events and insurance claims at real estate buildings across its portfolio. In addition, the individual real estate buildings within Intercontinental’s portfolio generally maintain physical security systems, policies, and procedures which are implemented by the property manager and designed to protect the tenants and building from physical threats including fire, security breaches, and transmission of infectious disease. When Intercontinental constructs new buildings, it works with reputable architecture, engineering, and construction companies to meet or exceed local building codes that relate to physical resilience against events such as earthquakes and floods.
Finally, Intercontinental strives to monitor social risks to its business and the buildings in its portfolio. For example, the Asset Management group monitors Intercontinental’s legal obligation to provide affordable housing at the apartment buildings it owns. Intercontinental works closely with local communities and zoning boards to address community concerns when constructing new buildings and seeking permits to improve existing properties. At the company level, Intercontinental has supported employees with paid leave and through other means, to engage with social issues about which they are passionate and/or deeply affected.
Given the potential impact of climate-related physical, transition, and social risks, Intercontinental may consider developing performance metrics and targets to track progress towards adequately addressing and mitigating these risks, and to take advantage of any value creation opportunities.
Energy Consumption and Renewable Energy
Intercontinental strives to maximize the energetic efficiency of the buildings it operates or the portions of building it controls, as applicable, through direct means and engagement of relevant stakeholders. Energetic efficiency may reduce operating expenses and increase income while enhancing the competitive differentiation of a building and reducing its GHG emissions. Intercontinental is committed to measuring the energy consumption of its buildings (or those portions it controls, as applicable), launching an initiative to establish baseline data in 2020 and driving toward establishing targets in the future. Where possible and economically neutral or beneficial, Intercontinental strives to substitute energy from renewable sources in place of energy from non-renewable sources in order to decrease GHG emissions and mitigate risks relating to transition to a low-carbon economy. Intercontinental may decrease energy consumption through methods including operational improvements, stakeholder engagement, enhancements to building envelops, and equipment retrofits. Intercontinental may continue to seek third-party certifications such as Energy Star and LEED.
Intercontinental strives to optimize the waste management efficiency of the buildings it operates or those portions of building it controls, as applicable, through direct means and engagement of relevant stakeholders. Improvement of waste management practices may reduce operating expenses and increase income while enhancing the competitive differentiation of a building, reducing its GHG emissions, and otherwise mitigating environmental damage. Intercontinental is committed to encouraging employees, relevant vendors, property managers, and tenants (to the extent possible) to practice sound waste management including diversion of waste away from landfills and incineration. Sound practices may include limiting hazardous and non-hazardous waste, reuse, recycling, composting, recovery, and on-site storage that complies with local laws. More specific examples of sound practices may include: appropriate signage; dedicated recycling containers; dedicated biohazard waste containers; safe storage and recycling of waste related to cleaning products and other maintenance activities; separation of facility maintenance and renovation waste from ongoing source; and processes to recycle batteries, lamps, and other electronic waste.
Water Consumption and Management
Intercontinental strives to reduce water consumption and engage in sound water-management practices at the buildings it operates or those portions of building it controls, as applicable, through direct means and engagement of relevant stakeholders. Sound practices and efficiency with respect to water may reduce operating expenses and increase income while enhancing the competitive differentiation of a building, reducing GHG emissions, and otherwise mitigating environmental impacts. Intercontinental is committed to measuring the water consumption at its buildings (or those portion it controls, as applicable), launching an initiative to establish baseline data in 2020 and driving toward establishing targets in the future. Examples of sound practices include: management of issues relating to optimal usage in compliance with local laws; installation of efficient water fixtures meeting the standards of EPA WaterSense; installation of high efficiency irrigation systems; and xeriscaping.
Biodiversity and Habitat
Intercontinental recognizes the importance of preserving the biodiversity of natural habitats, and compliance with any laws or regulations focused on this issue. The operations of Intercontinental and its buildings typically occur in significant U.S. urban centers that were previously developed. Therefore, Intercontinental’s ability to influence biodiversity is typically limited.
Indoor Environmental Quality and Pollution Prevention
Intercontinental strives to maintain healthy indoor environments within the buildings it operates or those portions of building it controls, as applicable, through direct means and engagement of relevant stakeholders. Intercontinental may fulfill this objective through various means including preventative maintenance, green cleaning practices, and no smoking policies, undertaken either directly or encouraged through stakeholder engagement. Indoor air quality may be optimized through selective upgrades of HVAC systems and preventative maintenance, for example: outdoor air intake opening and exchange; air filtration; humidification equipment and controls; use of ultraviolet light to mitigate airborne pathogens; distribution systems; and exhaust fans. Green cleaning may include specific strategies, procedures, and cleaning products that are certified by neutral third parties like Green Seal, EPA Safer Choice, USDA BioPreferred, and UL ECOLOGO.
Sustainable Procurement, Material Sourcing and Environmental Attributes of Building Materials
Intercontinental recognizes that products purchased directly and by stakeholders, to sustain the operations of its company and buildings, may have variable and meaningful impact on the environment over the course of the products’ life cycle from material sourcing, to manufacturing, to use and disposal. Intercontinental strives to understand the environmental impact of the products used in operations and establish a process and incentives that facilitate the procurement of sustainable products. Intercontinental may consider products manufactured with the maximal amount of recovered material feasible, environmentally preferable products (such as rechargeable over disposable batteries) whenever cost effective, and lamps with low or no mercury content. Intercontinental may consider sourcing materials (directly or via third-party contracts) that have the following attributes, certifications, and labels: Energy Star appliances, electronics, light bulbs, lamps, office and HVAC equipment; EPA Comprehensive Procurement Guidelines for recycled materials and products; clean products referenced in indoor air quality section above; EPEAT electronics; EPA Water Sense water system products; Forest Stewardship Council paper products; Rainforest Alliance office supplies, kitchen products, printing services, and furniture; BIFMA e3 Furniture Sustainability Standard furniture; GreenGuard office supplies, kitchen products, printing services, and furniture; Cradle to Cradle Certified cleaning products, office supplies, restroom supplies, office furniture, and carpeting; FloorScore floor coverings; NSF-140 carpeting; Sustainable Agriculture Network’s Sustainable Agriculture Standard for bio-based products tested by ASTM Test Method D6866; Health Product Declaration (HPD) end products with published, complete disclosure of known hazards in compliance with HPD Open Standard; Environmental Product Declaration (EPD) products having an environmental product declaration that conforms to ISO 14025, 14040, 14044, and EN 15804 or ISO 21930 and have at least a cradle-to-gate scope.
For corporate offices specifically, Intercontinental may consider: reduction in packaging due to purchases; establishing a program to purchase environmentally preferred products at cost-effective prices if possible; use of Energy Star copy machines; use of FSC-certified and recycled-content paper and printing two-sided when feasible; recycling of ink cartridges; for kitchens purchasing re-usable or compostable cups, forks, spoons, knives, and plates.
New Construction and Major Renovations
Intercontinental has an ESG strategy in place for development projects, including new construction, redevelopment, and major renovations. Where feasible, Intercontinental references current third-party green building standards, such as Institute for Real Estate Management (IREM) Certified Sustainable Property and Leadership in Energy and Environmental Design (LEED) guidelines applicable to the specific property type involved, in areas that specifically address site selection and land use, sustainable site design and development, energy efficiency and water conservation, occupant health and well-being, worker safety, indoor environmental quality, material sourcing, and waste management Development projects also consider resilience strategies, including risk management and value creation for transition, physical, and social risks.
Site Selection and Land Use: Intercontinental considers various sustainability site-selection criteria for development projects, including the development status of adjacent properties and local area, allowances for redevelopment of brownfield sites, and connectivity to multi-modal transit networks. Where relevant, sustainability site-selection criteria also include the protection, restoration, and conservation of aquatic ecosystems, farmland, floodplain functions, habitats for native, threatened and endangered species, and historical and heritage sites.
Sustainable Site Design & Development: All development projects aim to reduce detrimental impact on the environment and surrounding communities. As such, Intercontinental has requirements which relate to: performing an environmental site assessment; managing waste by diverting away from disposal construction and demolition materials, rocks, and soil; minimizing light and noise pollution to the surrounding community; protecting air quality during construction; protecting and restoring habitats and soils disturbed during construction and/or previous development; and controlling and retaining construction pollutants to protect surface water and aquatic ecosystems.
Energy Efficiency & Water Conservation: Intercontinental’s development projects strive to include minimum energy efficiency requirements, promote water conservation, and implement monitoring for energy and water consumption. Common energy efficiency measures are adopted for air conditioning, space heating, ventilation, water heating, lighting and other high efficiency equipment and appliances, occupant controls, passive design and energy modeling, and commissioning. Common water efficiency measures adopted include drought tolerant or low-water landscaping, high-efficiency fixtures, leak detection, and sub-meters. Development projects incorporate sub-meters for energy and water, as well as building energy management systems, and energy use analytics. Intercontinental recognizes the importance of buildings in addressing climate change, and therefore aspires to incorporate on-site renewable energy, and potentially net-zero-carbon, design standards in select projects.
Occupant & Community Health and Well-Being: All development projects, through commissioning and design processes, address common occupant health and well-being measures, including acoustic and thermal comfort, features which are biophilic, active, and inclusive, daylight and illumination, indoor air quality and natural ventilation, occupant controls and workplace ergonomics, and water quality. Intercontinental also strives to evaluate the potential socio-economic impact of development projects on the community as part of planning and pre-construction, including housing affordability, impact on crime levels, livability and walkability scores, local income generation and job creation, and residents’ overall well-being.
Worker Safety: Intercontinental prioritizes the health and safety of building tenants and contract service providers using the facility during development projects. As such, safety is promoted through the availability of medical personnel and/or on-site professionals trained in health and safety, personal-protective and life-saving equipment (including requiring VOC-safe respirator masks for workers installing any products containing over 150 grams per liter of VOCs), communication of safety information and goals of the indoor air quality construction plan using safety meetings, signage, and subcontractor agreements; demonstration of safety leadership and entrenchment of safety practices; promotion of design for safety; and provision of training curricula. To support continuous improvement in safety performance and manage safety risks, worker safety metrics are tracked on all construction sites, including injury rates, fatalities, near misses, and lost day rates.
Indoor Environmental Quality: To enhance ventilation and indoor air quality for development projects, Intercontinental projects are required to: seal off air supply and return vents to protect the ventilation system components from contamination and/or clean ductwork and ventilation components thoroughly prior to occupancy; provide a continuous minimum ventilation rate of 1 air change per hour during construction or conduct a flush-out for three days at 100% outside air, after construction ends and prior to occupancy; provide a minimum of MERV 8 filtration on return air system if operated during construction, and replace filter(s) prior to occupancy; provide supplemental ventilation for at least 72 hours after work is completed during installation of carpet, primer, paints, adhesive, furnishings, and other VOC-emitting products; and follow the recommended control measures of the Sheet Metal and Air Conditioning National Contractors Association (SMACNA) IAQ Guidelines for Occupied Buildings under Construction, 2nd edition (2007), ANSI/SMACNA 008–2008, Chapter 3. Furthermore, Construction areas are guided by policies and procedures to: erect temporary dust curtains to separate work area from other occupied space and prevent dust transmission; provide walk-off mats to prevent tracking and dust from construction area; protect porous and fibrous materials from absorbing volatile organic compounds (VOCs); maintain dry work areas to prevent moisture damage; clean dust immediately after construction activity; close containers when not in use; provide N-95 or better dust masks to workers who are generating dust or particulates, such as deconstruction or sanding drywall or wood; use safe, low-toxic cleaning supplies for surfaces, equipment, and workers’ personal use; and conduct regular inspection and maintenance of indoor air quality measures including ventilation system protection and ventilation rates.
Material Selection: Intercontinental considers environmentally preferable product alternatives unless such products are not available within a reasonable time, at a reasonable price, or are not life-cycle cost efficient in the case of energy consuming products, or do not meet reasonable performance standards. The types of materials selected may meet the following third-party certifications and standards: U.S. EPA Safer Choice; C2C (Cradle to Cradle); SCS (Scientific Certification Systems); Green Seal; BIFMA (Business and Institutional Furniture Manufacturer’s Association) Product Safety and Performance Standards and Guidelines; GREENGUARD Label; CRI Green Label and Green Label Plus (Carpet and Rug Institute); and International Living Future Institute’s Declare Database. During construction, Intercontinental strives to use durable products, reusable products and products (including those used in services) that contain the maximum level of post-consumer waste, post-industrial and/or recyclable content, without significantly affecting the intended use of the goods or services (a cost analysis may be required in order to ensure that such products are made available at competitive prices). Moving forward, Intercontinental may consider exploring products with low embodied carbon emissions to further mitigate negative environmental impacts from material selection.
Waste Management: To promote efficient on-site solid waste management, Intercontinental reviews and discusses during pre-construction the waste management plan including responsibilities, anticipated types and quantitates of materials, methods and procedures for collection, handling and removal, salvage and reuse strategies, and recycling facilities to be used. Intercontinental instructs all subcontractors to educate and communicate procedures to their crews that comply with the plan, potentially including: to label all recycling containers clearly and provide signage that lists acceptable/unacceptable materials; to separate recyclable materials from construction and demolition waste (including recyclable materials by type) to the maximum extent possible; to removes construction and demolition waste from project site on a regular basis and transport waste materials off property for legal disposition; and to obtain receipts from waste haulers, salvage yards, and recycling centers. Though Intercontinental does not specify a diversion rate threshold, all development projects are expected to divert as much material from landfill as possible, in part by incentivizing contractors for recovering, reusing, and recycling building materials and conducting on-site monitoring of hazardous and non-hazardous waste.
Contractors: Intercontinental expects contractors it engages to adhere to ESG values, and therefore, requires contractors to comply with Intercontinental’s standards around business ethics, human rights, environmental process and product standards, human health-based product standards, occupational safety, and labor standards and working conditions (including prohibiting child labor).
Property Acquisition Criteria
Intercontinental incorporates environmental and social criteria in the process of acquiring new real estate buildings and properties. Intercontinental’s acquisitions process makes use of a due diligence checklist to ensure consistent and thorough application. The checklist includes a section to address environmental and social factors. ESG criteria incorporated into the checklist vary by sector (i.e. office, industrial, retail, multifamily) and according to whether new development is contemplated. Depending on sector and scope, criteria may include: biodiversity and habitat; building safety; climate change adaptation, including ability to manage relevant transition, physical, and social risks; compliance with environmental regulatory schema; land contamination; energy efficiency and supply; environmental risks; greenhouse gas emissions; health and well-being; indoor air quality; potential for natural hazards; socio-economic risks; transportation risks; waste management; and water efficiency and supply.
This is not an offer to buy or sell any financial instrument and does not constitute a recommendation of any strategy or product for a particular investor.