STATEMENT ON PRINCIPAL ADVERSE IMPACTS OF INVESTMENT DECISIONSON SUSTAINABILITY FACTORS
Product Name: Invincible Investment Corporation
Legal Entity Identifier: 353800JY6M2692VAV685
The following is the adverse sustainability impact statement of Invincible Investment Corporation (“INV”)
pursuant to Regulation (EU) 2019/2088 (“SFDR”). INV has no employees in accordance with the prohibition on
having employees under the Act on Investment Trusts and Investment Corporations of Japan, and relies onConsonant Investment Management Co., Ltd. (the “Asset Manager”) to manage and operate the properties in ourportfolio. INV and the Asset Manager are hereinafter referred to collectively as “we”, “us” or “our”. References
to “fiscal year” or “FY” are to the 12 months that began or beginning April1 of the year specified, unless noted
otherwise.
Please note that SFDR requirements, including the scope of their application to issuers outside the European
Economic Area, continue to evolve. We are therefore taking a principles-based approach to compliance with theSFDR disclosure standards, which are subject to change.
1. Summary
Pursuant to Article 4 of the Delegated Regulation C(2022)1931 supplementing SFDR (the “SFDR DelegatedRegulation”), INV is required to publish on its website the information referred to therein covering the period ofone calendar year. INV is a Japanese real estate investment trust, commonly known as J-REIT, and has noemployees, relying on the Asset Manager for the management and operation of its properties. The Asset Manager
operates based on a calendar year (INV’s 6-month fiscal periods end on June 30 and December 31 of each year),but as for the calculation of the GHG emissions data, the Asset Manager collects and compiles such data based on
fiscal year ending in March of ever year. A recalculation and translation of the data into the reference period of
one calendar year would most likely lead to inaccuracies and would therefore provide a potentially less accurate
overview of the required information than using the approved and validated data for the period from April 1, 2023
to March 31, 2024. This reference period is sufficiently compatible with, and shows results that do not materiallydiffer from, those that would be produced using the calendar year-based reference period noted in the SFDR
Delegated Regulation.
We consider principal adverse impacts of our investment decisions on sustainability factors. The present statement
is our consolidated statement of the principal adverse impacts on sustainability factors (“PAI”). The statement
covers the reference period from January 1, 2023 to December 31, 2023 other than the GHG emissions data inTable 2. The statement will be reviewed at least once during every year.
We recognize the importance of environmental, social, and governance (“ESG”) considerations in real estate
investment management from the viewpoint of sustainability such as economic and social development andcontributing to global environmental conservation, and regard improvement of sustainability as an importantmanagement issue.
We have established the basic policies for sustainability such as promotion of energy conservation and reductionof greenhouse gas, adaptation to climate change, water consumption efficiency, effective utilization of resources
and reduction of waste, improvement of health, safety and comfort of tenants and visitors, collaboration withtenants, supply chains and local communities and initiatives for employees on the belief that the incorporation ofESG considerations into the real estate investment management business, which is our primary business, is essential
to maximizing unitholder value over the medium to long term.
We use the definition of PAI as described in Recital 20 of SFDR being “those impacts of investment decisions andadvice that result in negative effects on sustainability factors,” with sustainability factors referring to environmental,social and employee matters, respect for human rights, anti‐corruption and anti‐bribery matters as defined in article
2 (24) of SFDR.
We believe that investment decisions that negatively affect climate or other environment-related resources, or havenegative implications for society, can have a significant impact to risk and value creation for our unitholders. To
this end, we consider PAI of our investment decisions throughout all major steps of the investment decision andproperty management process throughout the lifecycle of the properties in our portfolio.
2. Description of principal adverse sustainability impacts
Nearly all types of economic activity have the potential to impact various PAI indicators, both positively andadversely. We aim to manage the risk connected to PAI from our investment decisions in several ways, including
general screening criteria, due diligence and our ESG initiatives. Some of the PAI indicators listed below are
currently already being monitored and reported. As the availability of data improves, it is our intention that moreindicators will be added.

Table 1
Principal adverse sustainability impacts statement
We do not invest in investee companies, but invest in real estate. As adverse sustainability indicators 1-16
as contained in Table 1 of Annex 1 of the SFDR Delegated Regulation pertain to investee companies,
these are not included in this PAI statement, which pertains to real estate investments.
Indicators applicable to investments in real estate assets
Adverse sustainability
indicator

MetricImpact in
2023

Impact in
2022

Explanation

Actions taken

We do notinvest in realestate assets
involved in theextraction,storage,transport ormanufacture offossil fuels.

N/A

Fossilfuels

17.
Exposure
to fossil
fuels
through
real estateassets

Share ofinvestments inreal estateassets involvedin theextraction,
storage,transport or
manufacture offossil fuels

N/A

N/A

Energyefficiency

18.
Exposure
to energyinefficient
real estate
assetsShare ofinvestments inenergyinefficient realestate assets

As ofDecember 31,2023, 77.9%
of ourpropertiesare classified
as energyinefficient realestate assets.

To track theAs of
December 31, environmental
2022, 87.1% performance ofour properties, weof ourrely onpropertiesare classified certifications
issued by third
as energyinefficient real party
estate assets. organizations,such as the
Building Housing
Energy efficiency
Labeling System("BELS")
Evaluation, andother equivalentcertifications.
With respect toBELS
certifications, weconsider aproperty to havesufficientenvironmental
certification if it
received 2 stars or
higher out of
BELS' five-starranking system.

We implement
as appropriate
measures toreduce theirenvironmental
impact of ourproperties.
Also, we set
Key
Performance
Indicators(“KPIs”) andtargets
regardingenergyefficiency andmonitor throughtheSustainabilityCommittee.

Table 2
Additional climate and other environment-related indicators
INV does not invest in investee companies, but invests in real estate. As additional climate and otherenvironment-related indicators 1-17 as contained in Table 2 of Annex 1 of the SFDR DelegatedRegulation pertain to investee companies, these are not included in this PAI statement, which pertains toreal estate investments.
Adversesustainability
impactAdverse sustainability impact (qualitative or quantitative)

MetricIndicators applicable to investments in real estate assets
Greenhouse gas
emissions

18. GHG emissions
Scope 1 GHG emissions generated by real estate assets were 21 tCO2 (in FY2019), 21 t-CO2 (in FY2020), 17 t-CO2 (in FY2021), 17t-CO2 (in FY2022) and 12 t-CO2 (in FY2023).
Scope 2 GHG emissions generated by real estate assets were 738 tCO2 (in FY2019), 706 t-CO2 (in FY2020), 702 t-CO2 (in FY2021),
659 t-CO2 (in FY2022) and 633 t-CO2 (in FY2023).
Scope 3 GHG emissions generated by real estate assets were 30,645
t-CO2 (in FY2019), 23,818 t-CO2 (in FY2020), 25,003 t-CO2 (inFY2021), 25,801 t-CO2 (in FY2022) and 25,908 t-CO2 (in FY2023).
Total GHG emissions generated by INV’s portfolio were 31,405 tCO2 (in FY2019), 24,546 t-CO2 (in FY2020), 25,722 t-CO2 (inFY2021), 26,477 t-CO2 (in FY2022) and 26,553 t-CO2 (in FY2023).
We aim to reduce GHG emissions intensity (aggregate amount of
Scope 1 and 2) of our portfolio by 5% over five years from FY2019.
Furthermore, we aim to reduce GHG emissions intensity (Scope 3and aggregate amount of Scope 1, 2 and 3) of our portfolio by 1%
over five years from FY2019.

Scope 1 GHG
emissions generated
by real estate assetsScope 2 GHG
emissions generated
by real estate assets
Scope 3 GHG
emissions generated
by real estate assets
Total GHG
emissionsgenerated by realestate assets

Table 3
Additional indicators for social and employee, respect for human rights, anti-corruption andanti-bribery matters
INV has no employees in accordance with the prohibition on having employees under the Act on
Investment Trusts and Investment Corporations of Japan, and relies on the Asset Manager to manage andoperate the properties in our portfolio. Accordingly, additional indicators for social and employee,
respect for human rights, anti-corruption and anti-bribery matters in this PAI statement pertain to theAsset Manager and the tenants of the properties in our portfolio, to the extent available.
SOCIAL AND EMPLOYEE, RESPECT FOR HUMAN RIGHTS, ANTI-CORRUPTION
AND ANTI- BRIBERY MATTERS
Adversesustainability
impactAdverse impact on sustainability factors (qualitative orquantitative)

MetricIndicators applicable to investments to CIM or tenantsSocial andemployee
matters

Anti-corruption
and anti-bribery

6. Insufficient whistleblower protectionThe Asset Manager has established whistleblower protection
rules that allows its officers and employees (including temporaryemployees) to report or consult about potential harassment, fraud
or other inappropriate acts. In accordance with the Whistleblower
Protection Act of Japan, our rules protect whistleblowers byprohibiting mistreatment upon whistleblowing, allowing
anonymous reports and keeping whistleblowers’ reports
confidential, and stipulate procedures, including investigation
methods and disciplinary actions for those who are found to haveengaged in inappropriate behavior, to find and correct thereported acts. In addition to an in-house contact, a whistleblower
may consult an outside attorney who has no business relationshipwith the Asset Manager.
15. Lack of anti-corruption and anti-bribery policies
The Asset Manager has established the Code of Compliance andCompliance Manual, the Asset Manager stipulates in them that
all of its officers and employees are prohibited from providing
favors or benefits to civil servants of Japan or other countries or
persons deemed as such, in accordance with Japanese andinternational laws. Furthermore, provision or acceptance offavors or benefits that exceed the scope of courtesy that would beordinary course based on socially accepted conventions isprohibited whether any business-related transaction takes place
as a result or not.

17. Number of convictions and amount of fines for violation ofanti-corruption and anti-bribery laws
For tenants of our hotel properties, we conduct due diligence
review when entering into lease agreements and reject thosefound to have been fined for violations of anti-corruption and antibribery laws.
Based on internal audits and other reviews that has been conducted

Share of investments inentities withoutpolicies on theprotection ofwhistleblowers
All of the AssetManager’s officers andemployees are provided
whistleblower protection.

Share of investments inentities without policies
on anti-corruption andanti-bribery consistent
with the United Nations
Convention against
Corruption
The Asset Manager has
compliance policies
addressing anticorruption and antibribery that apply to allof its officers andemployees.
Numbers of convictions
and amount of fines forviolations of anticorruption and antibribery laws by investee
companiesNone of the tenants ofour hotel properties

to date, the Asset Manager has not found any favors or gifts that
contravene relevant laws. Moreover, there have been noviolations of corruption-related laws or administrative sanctions.

have, to the best of ourknowledge, been
convicted of or finedfor violations of anticorruption and antibribery laws.
None of the AssetManager or its officers
and employees havebeen convicted or finedfor violations of anticorruption or antibribery laws.

For description of actions which INV takes and will take with respect to the PAI indicators, please refer to our ESG
website: https://www.invincible-inv.co.jp/en/sustainability/index.html
3. Description of policies to identify and prioritize principal adverse sustainability impacts
Subject to data availability, we monitor the selected PAI indicators for the existing properties in our portfolio.
Prior to our investment in a property, we conduct due diligence review of the property, including ESG due diligence,
which includes selected PAI indicators. The due diligence findings related to selected PAI indicators are reportedand reviewed prior to the investment decision.
In order to conduct ESG-friendly management while maximizing the value of our properties, we have taken into
consideration ESG factors in our investment and asset management processes. The Asset Manager tracks andmonitors the property-level environmental performance indicators of our properties to assess the environmental
performance of our portfolio appropriately. The Asset Manager’s Sustainability Committee, which generally meetsat least four times a year, uses the data of environmental performance to assess progress made against sustainabletargets, and deliberates on necessary action plans in order to implement initiatives continuously and systematically
based on our Sustainability Policy. The Sustainability Committee consists of (i) the President and CEO, who is thefinal decision-maker, (ii) the general manager of the Asset Management Department and the general manager of
the Planning Department, who are responsible for executing sustainability initiatives, and (iii) officers andemployees that engage in promoting sustainability.
For further information, please refer to our ESG website:
https://www.invincible-inv.co.jp/en/sustainability/index.html

4. Engagement policies

Due diligence and screening
Prior to our investment in a property, the Asset Manager conducts due diligence review of the property, including
the assessment of compliance with applicable environmental laws and regulations, environmental performance anddisaster risks, as well as investigation into hazardous substances and soil contamination by obtaining environmental
assessment from third parties. We also do not consider investing in properties that do not meet the standards forsoil contamination and other environmental contamination in accordance with the related environmental laws andordinances. However, from time to time we invest in properties not meeting the standards as long as they are
deemed fixable promptly after the investment.

Engagement
We have introduced environmental provisions, which we refer to as “Green Lease” provisions, in our leases with
our tenants, under which tenants are required to collaborate on environmentally conscious measures and sharevarious environment-related data with us. As of December 31, 2023, Green Lease provisions had been introducedin 60.8% of our portfolio based on gross floor area.
We provide our hotel assets’ operators with documentation regarding sustainable hotel operations. We conduct
such education efforts and cooperate with them in order to decrease the burden on the environmental caused byhotel operations and improve hotel users’ consciousness about environmental issues.

5. References to international standards
We became a signatory as a supporter to the Financial Stability Board’s Task Force on Climate-related FinancialDisclosures (“TCFD”) established by the Financial Stability Board. We will provide disclosures in alignment withTCFD’s core elements in due course.

6. Historical comparison
See Table 1 and Table 2 above.