Identification of E&S Risks and Impacts Assessment:  CLAS identifies and manages E&S risks and impacts associated with its operations through the Environment, Health and Safety Impact Assessment (ESIA) and CLI Sustainable Building Guidelines (SBG). An ESIA is carried out as part of due diligence to ensure EHS and legal compliance considerations are factored in at all stages of a project. The existing identification of E&S risks and impacts and assessment system is generally in line with PS1 requirements. CLAS complies with government agency requirements and obtained approvals including occupancy permits and L&FS certificates from the respective government authorities.

E&S Policy: CLI has an EHS policy in place, defining E&S objectives and principles applied to all the CLAS operations. The policy is disclosed on-line (https://www.capitaland.com/en/about-capitaland/sustainability.html) and available to all employees, suppliers, service providers and partners.

E&S Management System and Program: CLI has an ESMS in place to ensure legal compliance, identification of E&S risks and impacts, and implementation of EHS standard operating procedures including safety management, emergency procedures applicable to all the CLAS operations. The ESMS is prepared in line with international management standards of ISO 14001 (environmental management) and ISO 45001 (OHS management). Following CLI’s ESMS, each CLAS property has procedures related to E&S management including safety management procedures, waste management procedures and emergency response procedures.

Organizational Capacity and Competency: CLAS has an EHS Committee which comprises the chief executive officer and management staffs including EHS managers represented by respective country members. At each property, EHS Management role is led by country general manager. Each property has a dedicated management team including an EHS manager position in charge, and relevant team and officers assigned including health and safety, pollution control, and internal auditing to oversee various E&S aspects during operations.

Emergency Preparedness and Response: As part of CLI’s ESMS, a Crisis Management Manual (CMM) is in place to address emergency situations covering all the CLAS operations. There are emergency response procedures (ERPs) prepared for each property including responsibilities and duties defined for various staff and departments following the CMM. The ERPs include evacuation, fire, medical emergency, accidents, robbery, power failure and relevant natural disasters such as earthquake and typhoon.

Monitoring and Review: CLAS monitors all the operations in accordance with key performance indicators (KPIs) as part of CLI’s SBG KPI, such as energy efficiency, water and waste management, OHS, stakeholder engagement and supply chain management. Each property’s management team is in charge of monitoring and reporting to CLAS management on a quarterly basis. Internal audits are scheduled at least once a year and external audits are scheduled annually with an accredited third-party certification body.

CLAS has about 1,500 employees across all the properties managed by CLAS’ Sponsor (The Ascott Limited) and the manager of CLAS as of FY2021, comprising an almost equal proportion of males and females at a ratio of 48:52. Each property under the project has about 20 to 60 full time staffs (25 to 35% are female), and some contractors are hired such as security guards, housekeeping workers and engineering technicians.

Human Resources Policies and Procedures: CLI has a group level HR policy and guidelines applicable to CLAS, including its contractors. CLAS prepares employee handbooks following each country’s legal requirements. These HR policies and employee handbooks are generally consistent with IFC PS2 requirements, including working hours, overtime limits and payments, annual and maternity leave, salary and benefits, social insurance, health insurance, accident insurance, and resolution of labor disputes.

Working Conditions and Terms of Employment: All the employees including each property under the project have an employment contract with the key employment terms and conditions including the job description, duration of employment, working hours, salary and allowances, leave entitlements, welfare and social security, probation and notice periods, provision of training and key insurance and health security etc.

Workers’ Organization: According to CLAS management, the company respects its staff’s right to freedom of association (FoA) and being members of trade unions. Although currently there are no employee unions at the properties under the project in Philippines, there are seven employees in Indonesia who have joined a union including two employees from Ascott Jakarta. A collective agreement was developed and has been endorsed by the Department of Manpower for Jakarta Province covering all the employees of Ascott Jakarta.

Non-discrimination and Equal Opportunity: Non-discrimination and equal opportunity are described in the CLI’s corporate charter and various policies. These policies include principles to protect individual rights with a zero-tolerance stance towards child/forced labor, unlawful discrimination and sexual harassment which applicable to all the CLAS operations.

Worker Grievance Mechanism: All CLAS projects are covered by the CLI’s Whistleblowing Policy. At each CLAS property, employees can raise their grievances through CLI’s grievance process, face-to-face meeting with relevant management, or HR department. As per ESAP 1, CLAS will update its worker grievance mechanism procedure in line with IFC PS2 which will be available for its employees, and contracted workers, as applicable. This procedure will include steps to be taken by workers to manifest any concerns, engage in a mediation process, contact responsible persons, and provide timely feedback. The company will also reinforce the policy of confidentiality and non-retribution, along with ability to raise anonymous grievance.

Occupational Health and Safety: CLAS follows CLI’s OHS management system including identification of hazards and risk assessment, safe operations, OHS standard operating procedures. CLAS prepared asset operation and maintenance procedures applicable to all the CLAS properties.

All staff are required to take a mandatory OHS training covering; OHS overview, compliance requirements, incident reporting, safety and emergency preparedness. There are no fatalities nor major incidents including involving contractors that have been reported at the project facilities operation over the past three years. At each property, the management team is in charge of training for employees and coordinates provision of relevant OHS training with contracted companies.

There has been no significant health impact due to COVID-19 on the workforce. Each CLAS property prepared COVID-19 response procedures to ensure employee health and safety in line with government guidelines. There is no retrenchment conducted so far and/or anticipated.

Workers Engaged by Third Parties: No major construction activities are expected due to the project other than minor room improvements and enhancements activities which are developed by third party contractors selected. CLI’s contractor management guidelines applicable to CLAS require all contractors, including security, housekeeping and engineering, to comply with local government and other legal requirements, as well as its policies and procedures. Contractors are required to ensure that their staff are sufficiently trained or are briefed on EHS requirements such as the deployment of personal protective equipment, the reporting of accidents, and proper disposal of waste.

Supply Chain; CLAS follows CLI Supply Chain Code of Conduct (CoC) including human rights, health and safety, as well as environmental management and the legal compliance of local laws. Following the Supply Chain CoC, contractors are appointed upon meeting the environment, health and safety requirements. In 2021, all the CLAS’ suppliers acknowledged to abide by the CLI Supply Chain CoC as part of their new and renewed contracts.

 Resource Efficiency and Greenhouse Gas Emissions: CLAS assesses its operations to ensure energy and resource efficiency in line with group EHS policy and SBG. In year 2021, CLAS reduced its energy intensity by 25%, and water intensity by 45% from baseline year 2008. Some of the resource efficiency initiatives implemented include installation of LED lighting, efficient air-conditioning equipment and use of treated/recycled water. Ascott Jakarta and Ascott Makati achieved EDGE certification in 2020 and in 2019 respectively. CLI’s resource efficiency objectives include 35 % reduction of energy intensity by 2030 when compared to base year of 2008.

Based on data from the existing asset’s energy consumption, each property consumes about 2,000,000 to 8,000,000 kWh per year and total gross greenhouse gas (GHG) emissions is estimated to be about 8000 tons of carbon dioxide equivalent per annum (CO2 eq tpa). CLI has an objective to reduce GHG intensity by 78 % by 2030 when compared to base year of 2008.

Energy Supply and Air Emissions: Electricity is sourced from the national public grid for all the properties operations under the project in Philippines. In addition to the electricity from national grid, Ascott Jakarta uses some of the natural gas for the boiler rooms. Ascott Jakarta monitors ambient air quality on a yearly basis, and the monitoring reports indicate compliance with the applicable legal requirements. Small amount of diesel oil would be used by the backup generators installed but due to annual consumption, it is not expected to generate significant quantities of air emissions.

Water and Wastewater: Water for all the operations under the project is sourced from local municipal water supply system. The drinking water for employees and residents is sourced from local third-party water supply companies. The annual consumption of water by a property is about from 17,000 to 70,000 m3. There is no process wastewater generated from the project operations, other than for cleaning and laundry purposes. Domestic wastewater from the two properties in Philippines is discharged to the public sewage system. Wastewater treatment system installed in Ascott Jakarta prior to discharging public waterway. Ascott Jakarta has a discharge license and a standard operating procedure. Wastewater quality is monitored on a monthly basis and the monitoring report indicates there were no exceedances of the parameters stated within the discharge license.

Waste and Hazardous Material Management: Each CLAS property under the project has own waste management procedures to dispose and recycle waste including a system of appropriate handling, storage and disposal, which is consistent with the applicable legal requirements. All the waste is collected for disposal or recycling by an authorized public service agency or third-party company specializing in each type of waste. Hazardous materials are expected to be limited to cleaning and maintenance chemicals, dry cell batteries, used refrigerants and electric waste, which are stored with small quantities, segregated and disposed in line with the legal requirement by third-party authorized companies.

I Infrastructure and Equipment Design and Safety: CLAS has Fire Safety Design Guidelines applicable to all properties indicating structural fire precaution, means of escape, site planning and fire protection systems. CLAS’ product and technical services team reviews the fire safety provision. Each property has effective L&FS certificates from the respective government authorities and a set of procedures for fire safety describing actions to be taken as part of ERP.

The building structure was designed in strict compliance with the provision of the local structural code as well as other internationally accepted structural codes and standards. The structure was designed considering the effects of wind and seismic forces.

The properties that were visited, have maintained L&FS infrastructure and systems such as fire extinguishers, smoke detectors, fire alarms, emergency exits and signs and sprinklers. There have been no major fire accidents from the properties under the project in the past three years. Periodic briefings and annual evacuation drills are conducted at all properties. However, some properties do not have any specific provisions in place in terms of life and fire safety designated to handicap persons.

As part of ESAP 2: CLAS will develop a corporate plan to adapt the rooms that are used for handicap persons, making them suitable for its use during emergencies (i.e. adding features to help the visually or audible impaired people, mobility) including an intercom for area of refuge inside staircases.

Security Personnel: All properties under the project are guarded with unarmed security guards from licensed private security agencies. Qualification screening checks including criminal records were conducted when hiring. Regular training programs are conducted for the security workers on the standard operating procedures for their job including life and fire safety emergency trainings.

Stakeholder Engagement: CLI formed CapitaLand Hope Foundation (CHF) to support underprivileged children, vulnerable elderly and environment protection. CLAS also conducts own stakeholder engagement activities including donations, volunteering to local communities.

External Communications and Grievance Mechanism: CLAS publishes its annual Sustainability report (https://www.ascottresidencetrust.com/about-us/sustainability) every year. CLI has a whistleblowing policy and a stakeholder grievance handling procedure covering all the CLAS operations. There are the channels to receive stakeholder complaints through a public website (https://www.capitaland.com/en/more-from-capitaland/whisteblowing-policy.html) under CLI and grievances are directed to CLAS HQ. There has been no public complaints nor litigations with respect to the CLAS’ EHS and safety performance in the last three years.