Development Bank of Japan (“DBJ”)
Sustainability Bond Framework

Table of Contents
1. Outline and Approach to Sustainability of the issuer ......... 2
1.1 Outline of the issuer .......................................................................... 2
1.2 Corporate Philosophy and Materiality ............................................... 2
1.3 Sustainability Management ............................................................... 3
1.4 GRIT Strategy ................................................................................... 5

2. Rationale for Issuance ............................................................ 6
3. Alignment with the Green Bond Principles 2021 (“GBP”),
Social Bond Principles 2023 (“SBP”) and the Sustainability
Bond Guidelines 2021 (“SBG”) .................................................. 6
3.1 Use of Proceeds ............................................................................... 6
3.2 Project evaluation and selection process........................................ 11
3.3 Management of proceeds ............................................................... 12
3.4 Reporting ........................................................................................ 12

4. External Review..................................................................... 14
4.1 Second Party Opinion ..................................................................... 14

Appendix .................................................................................... 15

1

1.

Outline and Approach to Sustainability of the issuer

1.1 Outline of the issuer
Development Bank of Japan Inc. (“DBJ”) is a 100% government-owned financial institution
headquartered in Tokyo, Japan. DBJ provides domestic and global financial services to its clients,
operating across Japan, the U.S., Europe and Asia, with a mission to “Design the Future withFinancial Expertise”, and ultimately pursue sustainable development for Japan and the world.
DBJ’s history goes back to 1951 when the Japanese Government founded Japan Development
Bank as a governmental financial institution in order to support the recovery of the Japanese
economy, industry and society from the damage caused by World War II. Ever since, DBJ,
alongside with the Japanese Government has contributed to tackling the challenges facing Japanby providing financial solutions. The areas DBJ has contributed in include “Infrastructure
Development”, “Urban & Regional Development”, “Pollution Prevention and Environmental
Preservation”, “Energy Supply”, “Social Infrastructure Improvement” and “Crisis Response”.

1.2 Corporate Philosophy and Materiality
The DBJ Group’s corporate philosophy consists of a mission that it pursues relentlessly,
regardless of the times; core values that are shared by all of its executives and employees; andVision 2030, a vision for 2030 that it follows as a guide into the future.
<Corporate Philosophy>

To realize the future laid out in Vision 2030, the DBJ Group has identified its material issues, withreference to the concept of balancing economic and social value, which runs deep in the DBJ
Group’s sustainability management, and the objective prescribed in The Development Bank ofJapan Inc. Act, which is to contribute to the smooth supply of funds to those needing long-termbusiness funds, as well as to the sophistication of financial functions. Looking ahead, the DBJ
Group plans to review its material issues periodically from the perspective of balancing economic
and social value while maintaining dialogue with its stakeholders.

2<Materiality>

1.3 Sustainability Management
The DBJ’s sustainability management consists of a business model that leverages groupcapabilities in fields including integrated investment and loans and consulting and advisory
services. DBJ’s business model is designed to raise economic and social value simultaneously inpursuing a sustainable society for Japan and the world. DBJ works constantly to improve its value
creation process through collaboration and dialogue with stakeholders, seeking to refine its
sustainability management and enhance the value it creates.
<History of Commitment to Sustainability>
DBJ’s environmental sustainability activities started in 1960s as an initiative to counterenvironmental pollution problems caused by rapid economic expansion after the recovery fromWorld War II. With an aim to achieve the above sustainability goals, DBJ has aligned with UNEP
(United Nations Environment Program) since signing up to the “UNEP Statement by Financial
Institutions on the Environment and Sustainable Development” in 2011, as the first Japanesefinancial institution to sign up for the statement. In 2014 and 2016 respectively, DBJ became the only
Japanese investor member and a sole Japanese advisory board member of GRESB. DBJ issued its
inaugural green bond aligned with the ICMA Green Bond Principles (“GBP”) as Japan’s first issuer in
2014. Subsequently, with expansion of eligible assets in its framework, DBJ has issued sustainability
bonds continuously since 2015. DBJ was appointed as the first Japanese issuer member of the GBP
in 2017. Additionally, DBJ signed up to Principles for Responsible Investment (“PRI”) in 2016, andset up its Sustainability Management Office in 2017 under the Policy on Sustainability, which was
originally established as the Environment Policy in 2001. Most recently, DBJ got entered into anagreement with Task Force on Climate-related Financial Disclosures (TCFD) and also ratified theEquator Principles in 2020. In 2022, based on TCFD recommendations, DBJ declared the goal to3

achieve net zero GHG emissions by 2050, encompassing its own Scope 1 and Scope 2 emissions,as well as Scope 3 emissions of companies in its investment and loan portfolio.
<Sustainable Finance and Solutions>
DBJ has performed as a leader for sustainable finance and solutions in Japan. After being the first
financial institution in the world to develop an environmentally rated loan program (the DBJ
Environmentally Rated Loan Program) in 2004, DBJ expanded its menu of financing options thatfactor in the level of sustainability management at a corporation to include the DBJ BCM Rated Loan
Program and the DBJ Employees’ Health Management Rated Loan Program. DBJ emphasizes
dialogue with customers in the provision of these loan programs, as well as in the DBJ Sustainability
Linked Loans with Engagement Dialogue and its consulting services, and it assists customers withsustainability management. Also, in 2011, it created DBJ Green Building Certification, and it
conducts sustainability assessments of real estate properties.

<Commitment to Sustainability>41.4 GRIT Strategy
As a part of their fifth medium-term management plan (released in May 2021), DBJ promotes the“GRIT Strategy” for realizing a sustainable society, including initiatives to address climate change.
This is in line with the Japanese Government’s environmental policy with the aim to achieve 46%
GHG emission reduction by FY2030 (from FY2013) and carbon neutrality in 2050.
Out of ¥13 trillion total investments and loans target set out in the fifth medium-term management
plan, DBJ aims to provide ¥5.5 trillion over 5 years as investments and loans under the GRIT
Strategy.
<Details of GRIT Strategy>
G – Green: Initiatives to become carbon neutral with established technologies
R – Resiliency & Recovery: Building of flexible yet strong industrial foundations as well as safe andsecure regions and society
I – Innovation: Initiatives for innovations that are commercially feasible from a long-term perspective
T – Transition / Transformation: Strategic initiatives to steadily lead transition toward carbon
neutrality and other goals, based on current business foundation

5

2.

Rationale for IssuanceThrough the issuance of Sustainability Bonds, DBJ aims to contribute to the realization of asustainable society and environment as a responsible issuer. DBJ Sustainability Bond Frameworklays the groundwork for helping DBJ to promote the GRIT strategy and to achieve the goal of net
zero emissions of greenhouse gases by 2050.

3.

Alignment with the Green Bond Principles 2021 (“GBP”), Social Bond
Principles 2023 (“SBP”) and the Sustainability Bond Guidelines 2021(“SBG”)For the purpose of issuing Sustainability Bonds, DBJ has created the following DBJ Sustainability
Bond Framework, which addresses the four core components of the Green Bond Principles 2021(“GBP”), Social Bond Principles 2023 (“SBP”) and the Sustainability Bond Guidelines 2021 (“SBG”):
use of proceeds, project evaluation and selection process, management of proceeds, and reporting.

3.1 Use of Proceeds
Eligibility Criteria
The net proceeds, or an amount equal to the net proceeds, of the issuance of the DBJ Sustainability
Bonds will be allocated, by way of various financial instruments, exclusively to finance or refinance(“Eligible Financing(s)”), in whole or in part, existing and/or future projects or businesses which meetthe following Eligibility Criteria. The look-back period for refinanced Green and Social Eligible
Financing(s) will be 36 months prior to the date of the DBJ Sustainability Bond issuance.

1. Climate Resiliency / Climate Change Mitigation (Green Eligible Categories)
GBP Eligible
Green Project
Category
Green buildings

Eligibility Criteria

Environment
al Objective(1) Funds to finance or refinancebuildings which meet one of thefollowing:a. DBJ Green Building Certification
Program2: 5,4 or 3 stars
b. LEED (Leadership in Energy andEnvironmental Design):
Platinum, Gold or Silverc. BREEAM (Building Research
Establishment Environmental
Assessment Method):
Outstanding, Excellent or Very
good

Climatechangemitigation

1

Alignment with UN
SDGs1

This SDGs mapping refers to A High-Level Mapping to the Sustainable Development Goals by ICMA.
https://www.icmagroup.org/assets/documents/Regulatory/Green-Bonds/June-2020/Mapping-SDGs-to-Green-Social-andSustainability-Bonds-2020-June-2020-090620.pdf
2
DBJ website https://www.dbj.jp/en/service/finance/g_building/index.html
6

d. CASBEE (Comprehensive
Assessment System for Built
Environment Efficiency):
S, A or B+ Ranke. BELS (Building-Housing Energyefficiency Labelling System):
5, 4 or 3 stars
f. ZEB, Nearly ZEB, ZEB Readyand ZEB Oriented / ZEH, Nearly
ZEH, ZEH Ready and ZEH
Oriented (, all of which
represents the same or higher
level of performance comparedto BELS 5 Star)(2) Funds to finance or refinancecompanies, buildings, real estate
properties or REITs that have a ‘GreenStar’ rating under the Global Real Estate
Sustainability Benchmark (“GRESB”)
evaluation framework.

Renewableenergy(3) Funds to finance or refinancebuildings with high environmental
scores, which meet one of the following;a. Based on Tokyo Metropolis
Building
Environment
plan
system, both Perimeter Annual
Load (“PAL”) reduction rate andEnergy Reduction Ratio (“ERR”)
are in the top two levels for
retrofitting existing buildings to be
more energy efficientb. For commercial real estates,buildings which meet the CBIcriteria set for relevant cities(Tokyo’s criteria would be used
for Japan)3
c. For data centers, buildings withPUE
(Power
Usage
Effectiveness) below 1.5
Funds to finance or refinance renewableenergy projects below the threshold of
100g of CO2 per kWh:a.

3Construction, acquisition,
maintenance, and/or operationof solar, wind (onshore andoffshore), biomass (involving
wood pellets certified with FSC,
PEF or Sustainable Biomass

https://www.climatebonds.net/standard/buildings/commercial/calculator#calculator
7

Climatechangemitigation
Pollution
prevention
and control

Cleantransportation

Program (SBP) certification andpalm kernel shell), geothermal,
run-of-river hydropower, andtidal and wave power assets
Funds to finance or refinance cleantransportation projects or loans tocompanies exclusively for use forclean transportation projects:4a.

Installation and/or maintenanceof energy-efficient and/or
electric trainsb.

(Re)construction, extension,
maintenance, and/or upgradeof rail lines

c.

(Re)construction, maintenance,
operation and/or upgrade ofrailway systems and assets

Pollution
prevention
and controld.

EnergyEfficiency - DBJ
Environmentally
Rated Loan
ProgramInfrastructure and components
which could help increase thetransport capacity and improvethe efficient movement
Loans to companies that are rated A, B
or C under the DBJ Environmentally
Rated Loan Program5

Climatechangemitigation

Climatechangemitigation
Pollution
prevention
and control

4

DBJ confirms that in lending to companies, it is able to track use of loans from sustainability bond proceeds to ensure that the loans
are directed towards eligible clean transportation projects. DBJ also confirms that the amount of loans from sustainability bondproceeds will be equal to or less than the amount of CAPEX or OPEX spent by companies on eligible clean transportation projects.
5https://www.dbj-sustainability-rating.jp/en/enviro/
8

2. Disaster Resiliency (Social Eligible Categories)
SBP Eligible
Social Project
Category
Employment
generation,and programs
designed toprevent and/or
alleviate
unemployment
stemming fromsocioeconomic
crisesEligibility Criteria

Target Population andSocial objectives

Funds to finance or refinance businesses
negatively impacted by the economic
slowdown from socioeconomic crisis andnatural disasters through DBJ’s
respective socioeconomic crisis financing
programs, such as the Regional
Emergency Response Program

Affordable
basic
infrastructure –Power cableand grid
upgradeFunds to finance or refinance electric
power cable and grid extensions andupgrades mainly for disaster preparation
or reconstruction (the extensions andupgrades may also be included where it
contributes to higher efficiency of the grid,and to facilitate the connection ofrenewable energy sources to the general
network)

Supporting vulnerable
groups that may
include the generalpublic by providing
necessary funds tobusinesses negatively
impacted by the
economic slowdown
from socioeconomiccrisis and natural
disasters
Supporting vulnerable
groups that may
include the generalpublic by providing
necessary funds toaffordable basic
infrastructure projects.

(Energyefficiency Efficient power
grid)Socioeconomicadvancement
andempowerment- DBJ BCM
Rated Loan
Program

6

Loans to companies rated A, B or C
under the DBJ BCM Rated Loan
Program6

https://www.dbj-sustainability-rating.jp/en/bcm/
9(Climate change
mitigation)
Supporting vulnerable
groups that may
include the generalpublic by promoting
companies’ efforts totake measures fordisaster prevention,
BCP/BCM, and crisis
management

Alignmentwith UN
SDGs

3.

Healthcare & Social Well-being (Social Eligible Categories)

SBP Eligible
Social Project
Category
Affordable
housing

Eligibility Criteria

Target Population andSocial objectives

Funds to finance or refinance housingbusiness serving vulnerable populations,such as affordable housing

Access toessential
services healthcare

Funds to finance or refinance loans todomestic healthcare companies, whichmeet one of the following criteria;
1. Financing, acquisition,
maintenance and operation of
public hospitals and hospitals run
by a social medical care
corporation or a social welfare
corporation and nursing homes
2. Financing of medical carefacilities, medical equipment andproduct manufacturers that
contribute to treating andpreventing the spread of
infectious diseases and financingof pharmaceutical companies
contributing to testing and R&D
toward alleviating symptoms andpreventing the spread of
infectious diseases
Loans to companies rated A, B or C
under the DBJ Employee’s HealthManagement Rated Loan Program7

Supporting
underserved people,
but may also include
the general public,
needing access toessential services
including healthcare
and social well-being
Supporting
underserved people,
but may also include
the general public,
needing access toessential services
including healthcare
and social well-being
and vulnerable groups
that may also include
the general public byenhancing access topublic essential
services in healthcare

Socioeconomicadvancement
andempowerment- DBJ
Employee’s
HealthManagement
Rated Loan
Program7

https://www.dbj-sustainability-rating.jp/en/health/10Supporting generalpublic by promoting
companies’ efforts totake measures for the
improving the qualityof life and healthcareof their employees

Alignmentwith UNSDGs

Exclusionary criteria
DBJ has developed a list of exclusionary criteria to be applied to the allocation of the proceeds fromthe DBJ Sustainability Bond issuance. In this regard, DBJ commits to not knowingly allocating the net
proceeds for the financing of assets/projects/businesses included in the exclusionary criteria.

1. Businesses dedicated to the manufacture or retail sale and distribution of weapons and small
arms; or businesses dedicated to the production of products and services supporting the
manufacture or retail sale of weapons and small arms

2. Extraction, refining, or transportation of coal
3. Ownership or operation of dedicated gambling establishments/activities
4. Biomass plants designed primarily to consume food stocks
5. Large-scale (over 25MW capacity) hydropower dams

3.2 Project evaluation and selection process
Application of eligibility and exclusionary criteria in project selection
DBJ’s Treasury team is responsible for the selection of financial assets that meet the DBJ
Sustainability Bond Eligibility Criteria and for the allocation of the DBJ Sustainability Bond proceeds
to the selected financial assets. First of all, financial assets that would potentially meet the eligible
categories outlined in the framework are identified by the Corporate Finance Departments. The assets
identified by the Corporate Finance Departments are reviewed by the Treasury Department. The
Treasury Department judges eligibility of the potential assets. When necessary, Treasury Department
consults with the Sustainability Management Office and other relevant Departments. From overall
eligible assets pool, the Treasury Department selects the assets and allocates the Sustainability Bond
proceeds to the selected assets. Allocation per project category is expected to be determined within ayear after DBJ Sustainability Bond issuance.
Process to mitigate environmental and social risks
DBJ has the following processes that consider management of environmental and social risks in its
financing process:•

DBJ periodically monitors if borrowers comply with applicable regulations and laws (including
environmental laws), and if they obtain and maintain governmental permits, approvals,
licenses and authorizations. If a breach is expected to have a materially adverse effect, andnot cured within a grace period, DBJ is entitled to request prepayment subject to contractual
arrangements.

•

With respect to asset/structured/project finance, in some cases, DBJ engages an independent
consultant to undertake due diligence on environmental and social aspects. If this is not thecase, DBJ assesses the capability and reliability of the borrower in relation to identifying andmanaging environmental and social risks.

•

The Sustainability Committee, responsible for considering the incorporation of sustainability
and ESG insights into the DBJ’s usual business activities, discusses and considers the11balance between economic and social value (i.e. sustainability management), and maintains
communications with stakeholders on this topic.

3.3 Management of proceeds
The net proceeds, or an amount equal to the net proceeds, from the DBJ Sustainability Bond issuance
will be held and tracked in bond-by-bond approach by DBJ’s treasury until they are allocated to theeligible projects and/or businesses. Unallocated proceeds will be held in cash and/or a money-market
portfolio which will be tracked by DBJ Treasury Department. DBJ has internal management systems
to track the amount of funds allocated to each of the Eligible Financings.

3.4 Reporting
DBJ will report annually on its website the following information until full allocation of the net proceeds,
or an amount equal to the net proceeds, from the DBJ Sustainability Bond issuance:
1.

Allocation in aggregate to each eligibility criterion, and number of businesses/assets/projects
funded under each eligibility criterion

2.

The estimated share of financing and refinancing

3.

The amount of unallocated proceeds and the investments in which these proceeds are held.

Furthermore, DBJ will report on the following additional information and impact metrics on a best effort
basis:

12

Climate Resiliency / Climate Change Mitigation (Green Eligible Categories)
Type of eligible financings
Green Buildings

Additional information to be reported
DBJ Green Building Certification Program, LEED, BREEAM, CASBEE, BELS,
ZEB, Nearly ZEB, ZEB Ready, ZEB Oriented, ZEH, Nearly ZEH, ZEH Ready andZEH Oriented◼ Certification vintage◼ Subject to confidentiality and clients’ prior consent, two or three case studies
of underlying green buildings funded by the relevant Sustainability Bond
GRESB
◼ Certification vintage◼ Subject to confidentially and clients’ prior consent two or three case studies
of underlying REITs and real estate properties funded with the relevant
Sustainability Bond
Buildings with high environmental scores◼ Holding ratio to total floor area, property value, loan amount◼ Where feasible, primary energy consumption, actual or theoretical CO2
emission amount

Renewable Energy, Clean
Transportation◼ Distribution by sub-sector and location◼ Subject to confidentiality and clients’ prior consent, high-level description of
select projects◼ Where feasible, quantitative assessment of expected positive environmental
impacts on an aggregate basis◼ KPI: estimated carbon avoidance

Energy Efficiency - DBJ
Environmentally Rated Loan
Program◼ Certification vintage◼ Distribution by sector◼ Subject to confidentiality and clients’ prior consent, select project summaries,
rating and evaluation points

13

Disaster Resiliency (Social Eligible Categories)
Type of eligible financings

Additional information to be reported

Employment generation, andprograms designed to prevent
and/or alleviate
unemployment stemming fromsocioeconomic crises◼ Distribution by sector◼ Financing amount

Affordable basic infrastructure– Power cable and grid
upgrade◼ Subject to confidentiality and clients’ prior consent, high-level description of
select projects

Socioeconomic advancement
and empowerment - DBJ BCM
Rated Loan Program◼ Certification vintage◼ Distribution by sector◼ Subject to confidentiality and clients’ prior consent, select project summaries,
rating and evaluation points

Healthcare & Social Well-being (Social Eligible Categories)
Type of eligible financings

Additional information to be reported

Affordable housing◼ Number of residences provided

Access to essential services healthcare◼ Distribution by sub-sector◼ Hospitals: Number of hospital beds
◼ Pharma: Number of tests, or medicine distributed◼ Nursing homes: Care capacity

Socioeconomic advancement
and empowerment - DBJ
Employee’s HealthManagement Rated Loan
Program◼ Certification vintage◼ Distribution by sector◼ Subject to confidentiality and clients’ prior consent, select project summaries,
rating and evaluation points

4.

External Review

4.1 Second Party Opinion
DBJ has retained ISS-Corporate to provide a Second Party Opinion (SPO) on the environmental
benefits of DBJ Sustainability Bond Framework as well as the alignment to the GBP, SBP and SBG.
The SPO is available on DBJ’s website. https://www.dbj.jp/pdf/ir/credit/sri/202404_SPO_EN.pdf

14

Appendix
DBJ certification programs
DBJ certification programs are DBJ Environmentally Rated Loan Program, DBJ BCM Rated Loan
Program and DBJ Employee’s Health Management Rated Loan Program. DBJ provides loans tocompanies rated A, B or C and excludes companies rated “None”.

RatingA
B
C
None

Assessment
Companies with highly advanced / excellent initiatives
Companies with advanced / excellent initiatives
Companies with sufficient initiatives
Ineligible

DBJ Environmentally Rated Loan Program: https://www.dbj-sustainability-rating.jp/en/enviro/
DBJ BCM Rated Loan Program: https://www.dbj-sustainability-rating.jp/en/bcm/
DBJ Employees’ Health Management Rated Loan Program: https://www.dbj-sustainabilityrating.jp/en/health/

Perimeter Annual Load (PAL)
Thermal insulation of buildings(April 2014 ~)AAA

PAL * Reduction rate from the standard
value(PAL*reduction rate）
Over 20%

AA

Over 15% below 20%

Level 2

A

Over 10% below 15%

Level 2

B

Over 5% below 10%

Level 1COver 0% below 5%

Level 1Rating15

Relation to the evaluation level on thebuilding environmental plan
Level 3

Energy Reduction Ratio (ERR)
Energy efficiency of equipment system(April 2017 ~)RatingReduction rate of energy usage of the entire
facility system（ERR）

AAA

Use1： over 40% / Use2： over 30%

Relation to the evaluation level on thebuilding environmental plan
Level 3AA

Use1： over 30% below 40% / Use2： over 25%
below 30%

Level 3A

Use1： over 20% below 30% / Use2： over 20%
below 25%

Level 2

B

Over 10% below 20%

Level 1COver 0% below 10%

Level 1

※ Use1: Offices, schools, factories etc. / Use2: Hotels, hospitals, department stores, restaurants,
assembly halls etc.

Source: https://www7.kankyo.metro.tokyo.lg.jp/building/eva/outline.html

16Disclaimer
The information and opinions contained in this DBJ Sustainability Bond Framework (the Framework)
are provided as at the date of the Framework and are subject to change without notice. None of DBJ
or any of its affiliates assume any responsibility or obligation to update or revise such statements,
regardless of whether those statements are affected by the results of new information, future eventsor otherwise. The Framework represents current DBJ policy and intent, is subject to change and is notintended to, nor can it be relied on, to create legal relations, rights or obligations. The Framework is
intended to provide non-exhaustive, general information. The Framework may contain or incorporate
by reference public information not separately reviewed, approved or endorsed by DBJ andaccordingly, no representation, warranty or undertaking, express or implied, is made and no
responsibility or liability is accepted by DBJ as to the fairness, accuracy, reasonableness orcompleteness of such information. The Framework may contain statements about future events andexpectations that are forward looking statements. None of the future projections, expectations,estimates or prospects in this document should be taken as forecasts or promises nor should they betaken as implying any indication, assurance or guarantee that the assumptions on which such future
projections, expectations, estimates or prospects have been prepared are correct or exhaustive or, inthe case of assumptions, fully stated in the Framework. No representation is made as to the suitabilityof any Sustainability Bonds to fulfil environmental and sustainability criteria required by prospective
investors. Each potential purchaser of bonds should determine for itself the relevance of theinformation contained or referred to in the Framework or the relevant bond documentation for such
Sustainability Bonds regarding the use of proceeds and its purchase of Sustainability Bonds should
be based upon such investigation as it deems necessary. DBJ has set out its intended policy andactions in the Framework in respect of use of proceeds, project evaluation and selection, managementof proceeds and reporting, in connection with the Sustainability Bonds. However, it will not be an eventof default or breach of contractual obligations under the terms and conditions of any such Sustainability
Bonds if DBJ fails to adhere to the Framework, whether by failing to fund or complete Eligible Projects
or by failing to ensure that proceeds do not contribute directly or indirectly to the financing of the
excluded activities as specified in the Framework, or by failing (due to a lack of reliable information
and/or data or otherwise) to provide investors with reports on uses of proceeds and environmental
impacts as anticipated by the Framework, or otherwise. In addition, it should be noted that all of the
expected benefits of the Eligible Projects as described in the Framework may not be achieved. Factors
including (but not limited to) market, political and economic conditions, changes in government policy(whether with a continuity of the government or on a change in the composition of the government),changes in laws, rules or regulations, the lack of available Eligible Projects being initiated, failure tocomplete or implement projects and other challenges, could limit the ability to achieve some or all of
the expected benefits of these initiatives, including the funding and completion of Eligible Projects.
Each environmentally focused potential investor should be aware that Eligible Project may not deliver
the environmental or sustainability benefits anticipated, and may result in adverse impacts.

17