第21期（2021年1月期）決算説明資料
COMFORIARESIDENTIAL REIT

Sustainability
Report 2022
2021年3月

Contents

About this Report

Introduction
Top Messages

3

About CRR

4

Sustainability Policy / Structure for Promotion
Sustainability Initiatives

9

Materiality

11

Topics17

External Certifications / International Initiatives

19

Environment
Environmental Performance

22

Approach to Climate Change

23

Environmental Considerations

30

Considerations for recycling-oriented society

31

Establishment the Environment Management
System(EMS)

33

Urban Site Investment Criteria

34

Green Building Certification

35

Green Bonds

Comforia Residential REIT, Inc (“CRR”) and TLC REIT Management Inc.
(“TRM”) to which CRR entrusts its asset management, are making the best
effort to disclose information related to the sustainability initiatives to theinvestors and other stakeholders. Within this scope, this report is issued toillustrate the ESG (E: Environment, S: Society, G: Governance) initiatives at
CRR and TRM which are essential to contribute to a sustainable society.

Coverage on this report
PeriodFrom August 2021 to July 2022 (excl. some data)

Entities

CRR and TRM

Issued date

October 28, 2022
Contact

Dept.

Comforia Management Division, TLC REIT Management Inc.

37

Address

Shibuya Solasta 18th floor, 21-1 Dogenzaka 1-chome,
Shibuya-ku, Tokyo, Japan

Stakeholder Engagement40

E-mailinfo_comforia@tokyu-trm.co.jp

Employee Engagement

41

Initiatives to Local Communities

51

Initiatives to Tenants

52

Initiatives to Suppliers

54

Initiatives to Investors

57

Society

We communicate also using the Global Reporting Initiative (GRI) Sustainability
Reporting Standards, an international sustainability framework for ESG-related
reporting. About the GRI Standards, please refer to page 70.

Disclaimer

Governance
CRRʼs Corporate Governance60

TRMʼs Corporate Governance63

Initiatives for Governance Emphasizing
Unitholders’ Value68

GRI Content Index

70

Independent Assurance Statement

92

CRR and TRM do not guarantee or warrant the accuracy and safety of theinformation provided in this document and shall not be liable for updating
the information provided.
Please be advised that forward-looking statements provided herein may besubject to change or deletion without prior notice.

Introduction
Top Messages
From Executive Director of CRR

Takehiro Izawa
Executive Director
Comforia Residential REIT, Inc

Since our establishment, under the basic policies of “investments in residential
properties with high growth potential” and “utilization of the Tokyu Fudosan Holdings(“TFHD”) Group”, CRR has achieved internal and external growth by focusing ourinvestment in assets located in the 23 wards of Tokyo where has a strong demand forrental residences.
In the meantime, we have witnessed changes in social structure and lifestyle in Japan,such as decrease in population caused by declining birthrate and aging population;
migration of younger generations to metropolitan areas; change in residential preference
from ownership to renting; and the government-led workstyle reform.
In recent years, demand for corporations to respond to such social issues has increased,considering that these issues and changes may become a risk factor for corporate
business continuity. Triggered by the adoption of Sustainable Development Goals(SDGs) by the United Nations, the recognition that management focus on ESG(Environment, Society and Governance) will contribute to the enhancement of thecorporate value, has been widespread.
In light of this trend, our asset management company TRM established their
Sustainability Policy in April 2019 as their basic approach towards contributing to thedevelopment of sustainable society. We have created and issued this report for the
purpose of providing a comprehensive tool that may be used to gain more in-depth
knowledge of CRR and TRM’s aforementioned Sustainability Policy and ESG-related
initiatives. We hope that it will help our unitholders and other stakeholders understandour efforts.
CRR and TRM will continue fulfilling our social responsibilities by improving oursustainability initiatives, which we hope will strengthen the relationship of mutual trustthat we have built with our stakeholders.

3About CRR
Overview

Based on the Investment Trust and Investment Corporation Act (Act no. 198 of 1951 and subsequent revisions; hereinafter referred to as the “Investment Trust Act”),
CRR was established on June 8, 2010, as an investment corporation that mainly invests in real estate provided for residential use. We completed registration by theprime minister of Japan under Article 187 of the Investment Trust Act on June 30, 2010 (registration number: Director of Kanto Finance Bureau no. 71) and started
operation in August 2010. Subsequently, CRR issued new investment units based on a public offering on February 6, 2013, and was listed on the Tokyo Stock
Exchange’s Real Estate Investment Trust Securities Market (security code: 3282). When we began operation, CRR’s assets under management were 11 properties
with a total acquisition price of 15,5 billion yen; since then, as a result of steadily acquiring and selling properties based on the basic policy concerning assets undermanagement stipulated in our articles of incorporation (i.e., to manage assets with the aim of securing stable income and achieving steady growth of assets undermanagement in the medium to long term in order to maximize unitholder value), the number of assets we owned had reached 147 properties by the end of July 2022,with a total acquisition price of 281 billion yen.
Name

Comforia Residential REIT, Inc (TSE:3282)

Address

21-1 Dogenzaka 1-chome, Shibuya-ku, Tokyo

Representative

Executive Director, Takehiro Izawa

Fiscal Period

Six-month period from Feb.1 to Jul.31, and Aug.1 to Jan.31

Structure
Sponsor

CRR

2

TOKYU LAND CORPORATION
Comforia Residential REIT, Inc

6

Asset Management Company
TLC REIT Management Inc.

1

Unitholders’ Meeting

Asset Custodian
General Administration(operation of the administrative instruments)
Transfer Agent
Mitsubishi UFJ Trust and Banking Corporation

3

Board of Directors

General Administration (accounting, etc.)
Reiwa Accounting Holdings CO.,Ltd

7
Executive Director: Takehiro Izawa

Supporting Companies

Supervisory Director: Koji Yamamoto

4

Supervisory Director: Masamichi Ohshima
TOKYU LIVABLE, INC.
TOKYU COMMUNITY CORP.
Tokyu Housing Lease Corporation
National Students Information Center Co., Ltd.
TOKYU E-LIFE DESIGN Inc.
EWEL, Inc.
TOKYU SPORTS OASIS, Inc.

AuditorErnst & Young ShinNihon LLC

General Administration(tax)
Reiwakaikeisha(“RWK”)Tax Corporation

5

General Administration(Corporation Bonds)

Sumitomo Mitsui Trust Bank,Limited
MUFG Bank, Ltd.

❶Asset Management Agreement ❷Asset Custody Agreement / Administrative Service Agreement / Transfer Agency Agreement ❸Accounting Service Agreement❹Tax Administrative Agreement ❺Fiscal, Issuing and Payment Agency Agreement ❻Sponsor Support Agreement ❼Support Agreement

4About CRR
Basic Policies
We invest intensively in rental residences for singles and small families, mainly in the Tokyo metropolitan area, based on our basic policies of “investments in residential
properties with stable earnings and high growth potential” and “utilization of TFHD Group,” with the aim of ensuring stable earnings over the medium- to long-term andmaximizing our unitholders’ value.

COMFORIA Series
We will invest in and manage rental residences, fully utilizing the concept and expertise of the urban rental residence COMFORIA series, which Tokyu Land Corporation
has produced.

Value Chain of TFHD GroupWe have concluded sponsor support agreements, support agreements and property management agreements for managed assets with TRM and TFHD Group
companies to fully utilize the value chain and expertise of TFHD Group. With the support of TFHD Group companies through such agreements, we aim to expand ourasset size (external growth), and maintain and increase asset value (internal growth).

5

About CRR
Portfolio Management Policy
Investment Target Primary target: Maintain over 80% investment ratio of “Rental Residence” generating stable earnings.
 Sub-target: “Operational Rental Residence” with services likely to attract demand (i.e., senior residences, serviced apartments and student apartments.)

Asset Type

Investment Target

Investment ratio(acquisition price base)

As of
Jul.31,2022

Rental residence

80%～100%

93.2%

Operational rental residence

0%～20%

6.8%

Residential property

Rental residenceOver 80%(Note) Investment ratio is based on acquisition price. In terms of land with limited property rights, calculations are based on the type of residential property built on the parcel.

Investment Area
 Maintain over 80% investment ratio of assets in “Central Tokyo”, “Sub-central Tokyo” and “Tokyo Metropolitan areas”, where there is strong potential demand forrental residences.

Category

Investment Area

Central Tokyo

5 major wards

Chiyoda-ku, Chuo-ku, Minato-ku,
Shinjuku-ku, and Shibuya-ku

Sub-central
Tokyo

Dense residential districts
outside of the 5 major wards

Other Tokyo wards (excluding
above)

Tokyo
Metropolitan
area

Dense residential districts in allother Tokyo Metropolitan areas

All other areas within Tokyo
Metropolitan boundaries expecting
strong demand

Other major
citiesDense residential districts in ordinance-designated cities

Investment ratio(acquisition price
base)

As of
Jul.31,2022

80%～100%

95.5%

0%～20%

4.5%(Note) Investment ratio is based on acquisition price. In terms of land with limited property rights, calculations are based on the area where the parcel exists.

Tokyo area
Over 80%6About CRR
Features and Strengths
Portfolio focusing on “Tokyo 23 Wards” and “Near Stations”
When investing in properties, CRR selects them carefully, based especially on our location strategy for rental residences, with a focus on Tokyo’s 23 wards where
there are strong rental needs. Moreover, we have strategically built up our portfolio by continuing to emphasize properties located near stations, with the closest station
just a few minutes away on foot. As a result, 92% of the rental residences in our portfolio were located in Tokyo’s 23 wards as of the end of July 2022, and the averagetime on foot from rental residences to the nearest station was 5.0 minutes.

Tokyo 23 Wards

Near Stations

Investment area (Rental Residence)

Average minutes on foot from the nearest stations(Rental Residence)

Other major Cities
4.4%

Tokyo Metropolitan Area
3.6%

Sub-central Tokyo
54.5%

Tokyo 23 Wards

Central Tokyo
37.5%

92.0%

Over 10 min
4.3%

5 to 10 min
38.3%

Avg. Minutes
on Foot

Under 5 min
57.4%

5.0minUtilizing Support from TFHD GroupCRR aims to steadily increase our asset size and maintain and improve our asset value by using the support of the TFHD Group. The proportion of our properties
acquired from the TFHD Group as of the end of July 2022 was 72.7% (based on the acquisition price). In addition, the average occupancy rate since our listing is
95.9% (as of the end of July 2022).
Ratio of acquisition from the sponsor group（as of the end of Jul. 2022）

72.7％

Average occupancy rate since listing（as of the end of Jul. 2022）

95.9％
7

About CRR
Continuous expansion in asset size and sustainability initiatives
CRR aims to steadily increase our asset size and maintain and improve our asset value by using the support of the TFHD Group. Furthermore, we have positioned
sustainability initiatives as one of our priority strategies and are pursuing various environmental and social initiatives.
Asset size（bn yen）

Eligible Green Projects（bn yen）

2,259

2,060

2,266

2,459

2,521

2,615

2,615

2,810

1,644

712

Listed(Feb.6, 2013)

2 Properties
Certificated

1 Properties
Certificated

1 Properties
Certificated

1 Properties
Certificated

1 Properties
CertificatedSustainability Initiatives

142

133

132

243

298

334

327

325

368

End of 12th FP(Jul.31,2016)

End of 17th FP(Jan.31,2019)

End of 18th FP(Jul.31,2019)

End of 19th FP(Jan.31,2020)

End of 20th FP(Jul.31,2020)

End of 21st FP(Jan.31,2021)

End of 22nd FP(Jul.31,2021)

End of 23rd FP(Jan.31,2022)

End of 24th FP(Jul.31,2022)

September 2018GRESB Real Estate
Assessment on its First
Participation

April 2019
Establishment of
Sustainability Policies

September 2019
Acquired GRESB Real
Estate Assessment
Green Star ,GRESB
rating 3 Stars

July 2020
For the first time for
CRR of issuing green
bonds(1.5 bn yen for 10
years)

September 2020
GRESB rating 2 Stars

April 2021
Setting rules forsustainability
promotion framework

September 2021
GRESB rating 2 Stars
and Green StarFirst to obtain the Highest Rank
in the Residence Edition
Certification

COMFORIA SHINJUKUEASTSIDE TOWER

Acquired GRESB Real
Estate Assessment
Green Star ,GRESB
rating 2 Stars

Identification ofMateriality

May 2019
Inclusion in MSCIJapan ESG SelectLeaders Index

Aligning interests between unitholders and the sponsor

Establishment of
Sustainability
Department

August 2020
Change in
Asset Management
Fee System

July 2021
Issuing green bonds(3.0 bn yen for 10
years)

September 2022
Information disclosure
based on TCFD
recommendation
October 2021
First Issuance ofSustainability Report
December 2021
Signatory of PRI

As of the end of July 2022⇒

January 2022
Support for TCFD
recommendation

Sponsor’s investment ratio9.0％（64,674 units）

Feb. 2019
Issued 5,384units

Feb. 2020
Issued 3,079units

Feb. 2021
Issued 2,137units

Feb. 2022
Issued 2,410units

8

Sustainability Policy / Structure for Promotion
Sustainability Initiatives
TRM recognizes the impact of environmental and social considerations, and that of strong governance, and as a member of TFHD Group, shares TFHD Group’s
Sustainability Vision. TRM believes that tackling these issues is a social responsibility, realizes our management philosophy, and contributes to the development of asustainable society. The Sustainability Policies are established hereunder to implement the beliefs of TRM.
Sustainability Policies

Established April 1, 2019

1．Environmental Considerations
TRM will consider energy efficiency, decarbonization, water efficiency, and waste reduction as four major items in the operation of each investment corporation, andpromote our initiatives by applying these items to each environmental policy.
2．Efforts for Employees（1） TRM will improve employees’ sustainability knowledge, promote enlightenment activities for that purpose, implement capacity building to allow personnel to act
professionally and become more productive, provide training for human resource development, and support the acquisition of qualifications.
（2） TRM will promote efforts to improve the way employees work in light of the policies and practices of the entire Group and by closely sharing information in TRM.
3．Collaboration with External Stakeholders（1） As a member of the local community, TRM will enhance relationships with customers, such as tenants and facility users, and the local community throughimprovements in disaster prevention and BCP measures, contributing to safety and security.
（2） TRM will promote programs and procurement with environmental and social considerations through engagement with tenants and suppliers, including property
management companies.
（3） By means of the effective use of the expertise in real estate and other fields owned by TFHD Group's affiliates, TRM will be committed to improving customer
satisfaction while continuing to create value through each investment corporation.
4．Legal Compliance and Risk Management
TRM will comply with environmental, social, and governance laws and regulations as well as pay close attention to and appropriately respond to legislative changes.
For risk assessment upon real estate acquisition, TRM will work on risk management in an appropriate manner, taking into account environmental and social impacts.
5．Information Disclosure
TRM will strive to disclose information on our sustainability efforts to investors and other stakeholders.

9Sustainability Policy / Structure for Promotion
Promotion System
To enhance TRM’s efforts towards the issues related to environmental or societal consideration, etc. based on its Sustainability Policy, the rules on the Sustainability
Promotion System require that the President & CEO to be the Chief Sustainability Officer and each department appoint one responsible person from the department.
The Sustainability Promotion Council is to be held with the President & CEO as chairperson.
Sustainability Department was established as of April 1, 2021 to expand the functionality of the Sustainability Promotion System. The Sustainability Department
succeeds the ESG-related missions from the Environmental Engineering Department, and we will further promote our sustainability program.

Sustainability Promotion Council
The Sustainability Promotion Council meets regularly with President & CEO as the Chief Sustainability Officer who assumes the ultimate responsibility, and othermembers from across the organization of company and among members, we share relevant information and examine and promote the efforts. External experts areinvited to the Council to consult opinions when needed.
Important Agenda discussed at the Sustainability Promotion Council are regularly reported to the Asset Management Company's Board of Directors and as needed,
to CRR's Board of Directors as well.

Members of the Sustainability
Promotion Council

Chairperson

President & CEO

Regularmembers

Director, Chief Division Officers of the Comforia Management Division, Activia Management Division, andBroadia Management Division, Corporate Management Division, General Managers of Environmental
Engineering Department, and Sustainability Department, Compliance Officer

Organizer

Sustainability Department

Meeting frequency

Every quarter in principle

Main issues to be discussed

・Amendment and abolishment of the Sustainability Policy
・Amendment and abolishment of the Materiality
・Matters related to, and common to TRM and CRR・Annual activities planning, report on status

10

Sustainability Policy / Structure for Promotion
Materiality
As a member of TFHD Group, TRM recognizes the key issues (the “Materiality”) identified by TFHD Group and has identified its own materiality by extracting significant
medium- to long-term societal issues based on the tasks which CRR has been working on such as environmental issues. The Materiality has been shared with CRR.

Identification process
Materiality was identified by select cross-divisional members of TRM.

Step1

Awareness and organizationof societal issues

In preparing discussions for Materiality, societal
issues related to CRR and TRM were extracted byreferencing TFHD Group Integrated Report;materiality; GRI Standards; relevant SDGs; ESG
assessments for the real estate sector; and issues
recognized by the industry association.

Integration andconsolidation of issues

Step2

With respect to the above stated societal issues, amateriality short list was created after summarizing
the tasks which CRR and TRM has been working on,
and discussing topics that should be given higher
significance, with additional consideration to risks
and opportunities regarding each issue.

Step3

Reflection of opinions fromofficers and employees

All officers and employees were asked to offer
opinions as stakeholders of TRM, and preliminaryinterview was conducted with executive officer andsupervisory directors of CRR.

High

Step4 Identification of materiality
Materiality

Based on the interview results, significance ofeach issue to be addressed by CRR and TRM
was reviewed for appropriateness.
Materiality was identified by the Sustainability
Promotion Council and reported to the board of
directors of TRM and CRR.

（Significant societal issues）

Significance of
impact on economy,society, environment

Significance to Stakeholders, CRR and TRM

High

11

Sustainability Policy / Structure for Promotion
SDGs with close relevance to the Materiality
The Materiality, which is shared between CRR and TRM, is identified by considering the impact from a view of risks and opportunities, and the significance for us to address.
Our aim is to contribute to the SDGs (Sustainable Development Goals) through our commitment to the Materiality.
Materiality

Reducing environmental
impactHuman capitaldevelopment
as a group of
professionals

Contribution to theregionRisks（Impact of not addressing materiality）

Increased physical risk from escalation of climate change(human damage, property damage, economic damage),decarbonization society transition risks

Lack of sufficient skilled resources may hinder business
operation, leading to stagnant or lower unitholder value• Breakdown of communication with local community at timesof emergency such as disaster may cause reputational risk
• Risk of loss of liveliness due to the image of the invested
region becoming obsolete or due to population decrease

Opportunities（Business opportunities expected byaddressing materiality）

Relevant SDGs

• Share clear commitment to ESG investment with officers andemployees, providing opportunity for implementation andincorporation in our business strategy• Increased demand for leasing properties focused on
environmental performance
Each employee’s effort to further realize their abilities andmaintain mental health and stable living while fulfilling thefiduciary duty required of asset management business andworking towards our goal of maximizing unitholder value andenhancing our presence will create a positive cycle andimprove our performance.
Show presence by contributing to the safety and security of theregion and vitalization of local economy as a member of acorporate group committed to urban development

Contract renewal and repeated selection for relocation bytenants can be expected by creating safe, comfortable andpleasant space for tenants

Health and well-being of
tenants

Facilities with inferior ESG considerations may risk losing
support from tenants

Supplier engagement

Impact on management operation and deteriorated credit incase significant violation against sustainable procurement such Collaborate with suppliers to satisfy fiduciary duty required ofas discrimination, exploitation, destruction of nature,
asset management business and contribute to becoming thecontamination and violation of laws by suppliers are
REIT of choice by the investors
recognizedManagement framework
corresponding tomultifaceted social
demand towards
sustainable society

Inappropriate response to multifaceted social demands may
risk fall in trust concerning sound and effective managementbusiness and affect market development

Enhanced commitment to environment and society will further
promote establishment of medium- to long-term businessplatform, and improvement in financial value can be expected12Sustainability Policy / Structure for Promotion
CRR’s initiatives towards to each Materiality
Environment (E)Materiality

Reducing environmental
impactRelevant SDG Targets

PolicyStatus/Initiatives• Implementation of energy efficiency retrofits• Acquisition of environmental certifications/assessments, etc.
1.Energy use: Medium- to long-term target of 1% average annual• Efforts to improve waste management
reduction in energy use intensity.
• Introduction of green leases
2.Energy-related CO2 emissions: by 2030, 40% reduction in greenhouse• Monitoring by Sustainability Promotion Council
gas emissions intensity (vs.2020).
• Promotion of environment-friendly procurement through “Green
Procurement Standards”

7.3

By 2030, double the global rate of improvement in energy efficiency

12.5

By 2030, substantially reduce waste generation through prevention, reduction, recycling and reuse.

12.8

By 2030, ensure that people everywhere have the relevant information and awareness for sustainable development andlifestyles in harmony with nature.

13

Sustainability Policy / Structure for Promotion
CRR’s initiatives towards to each Materiality
Society(S)Materiality

Policy• Promote human resource strategy that indicates the requirements ofdesirable resources and facilitate development
Human capital development as• Commitment to health and well-being of each employee
a group of professionals• Deployment of measures based on Group KPIs (work-style reform,
promotion of diversity)

Status/Initiatives• Disclosure of key employee data to present our human resources strategy
and status of efforts on employee health and well-being (ratio of female
employees, number of female directors and managers, turnover ratio, stresscheck participation ratio, etc.)• Support acquisition of business knowledge, skills, qualifications, andimplement various trainings• Promote career development through periodic performance
evaluation/feedback• Periodic Health Committee• Introduction of various support systems leveraging on Tokyu Group
membership, etc.

1. Further improvement in disaster prevention functions
2. Prompt recovery of assets under management
3. Educational activities on fire and disaster prevention and disaster
response
4. Enhanced cooperation with local community• Capital expenditure from disaster prevention perspective• Public disclosure of evacuation sites/emergency reserves, etc.
• Relationship with local community （Corporation with local events, local
disaster prevention, disaster response and infectious disease prevention
etc.）

Health and well-being of
tenants• Improve tenant satisfaction• Check satisfaction via tenant survey and respond to comments by tenants• Distribute guide map on managed facilities• Deploy tenant service leveraging on group resources• Hold tenant participation events

Supplier engagement• Aim for smooth property management by utilizing expert know-how of
Tokyu Housing Lease, Tokyu Community, and other support agreement
counterparties in TFHD Group. Share information and actively work on
environmentally friendly procurement with PM/BM• Build and promote collaborative structure through periodic monitoring• Promote collaboration with all stakeholders through “Green Procurement
Standards”

Contribution to the region

11.3

By 2030, enhance inclusive and sustainable urbanization and capacity for participatory, integrated and sustainable humansettlement planning and management in all countries

12.8

By 2030, ensure that people everywhere have the relevant information and awareness for sustainable development andlifestyles in harmony with nature

Relevant SDG Targets

14

Sustainability Policy / Structure for Promotion
CRR’s initiatives towards to each Materiality
Governance(G)Materiality

PolicyStatus/Initiatives

1. Express statement on governance of the investment corporation• Governance of the investment corporation
Management framework
2. Express statement on investment decision making body and the riskcorresponding to multifaceted• Investment decision making body and the risk management system for
management system for investment
social demand towards
investment
3. Establish framework for promoting implementation of the Sustainability
sustainable society• Establishment of Sustainability Promotion Council for TRM
Policy12.8

By 2030, ensure that people everywhere have the relevant information and awareness for sustainable development andlifestyles in harmony with nature

16.7

Ensure responsive, inclusive, participatory and representative decision-making at all levels

Relevant SDG Targets

15

Sustainability Policy / Structure for Promotion
Relevance of the Materiality of CRR and TRM to that of TFHD GroupCRR・TRM

TFHD Group
Step1 Determination and organization of social issues
Generated a list of 470 items with reference to TFHD Group’s
management plans, the GRI Guidelines, ISO26000, the SDGs
Step2 Integration and consolidation of issues

Extractionof items

Step2 Integration and consolidation of issues

Selected 31 material issues with consideration of relevancy to TFHD
Group’s activities
Step3 Interview of management staff and experts

Step3 Reflection of opinions from officers and employees

Gather opinions from management staff and experts in specialized fields
Step4 Identification of Materiality
Verified the appropriateness of the importance of each issue andcategorized into seven

Materiality

Relevant SDGs

Step1 Awareness and organization of societal issues

Step4 Identification of materiality

Information
sharing
Materiality

Economic, political, and regulatory changes

Reducing environmental impact

Diversification and globalization of lifestyles

Human capital development
as a group of professionals

Safety and security in local communities andurban areas

Contribution to the region

Progression of a low birth rate and aging society

Health and well-being of tenants

IOT / Innovation
Changes in the natural environmentMore stringent social demands

Relevant SDGs

Supplier engagement
Management framework corresponding tomultifaceted social demand towards sustainable
society(Note)TFHD Group’s Materiality is those at the time of identification of Materiality for CRR and TRM

TFHD Groupʼs Code of Conduct, etc. that TRM shares as a member of TFHD GroupAs a member of TFHD Group, TRM does not only leverage TFHD Groupʼs comprehensive value-chain and expertise, but also shares the Code of Conduct and otherpolicies of TFHD Group.
16

Sustainability Policy / Promotion Framework
TopicsSupport for International Initiatives
Asset management company has announced support for PRI (Principles for Responsible Investment) and has been a signatory since December 2021.
Refer to “External Certifications / International Initiatives” (Page 19) for more details.
With the support for TCFD(Task Force on Climate-related Financial Disclosures), the asset management company has made a set of climate action
standards and making efforts to conduct information disclosure for CRR based on the TCFD recommendations.
Refer to “Approach to Climate Change” (Page 23) for more details.

CASBEE Certification for Real Estate
COMFORIA SHINJUKU EASTSIDE TOWER was the first residential REIT property to obtain the “S rank” of CASBEE Certification for Real Estate in December
2021. Consecutively, COMFORIA OMIYA also obtained the “S rank” in July 2022.
COMFORIA SHINJUKU EASTSIDE TOWERCOMFORIA OMIYA

17

Sustainability Policy / Promotion Framework
New Work Style Project
A voluntary team set up by asset management company employees launched a new project in October 2021, aiming to design and propose new work styles. Mainly
concentrated on 3 Topics as “office and digital environment’’ “internal Communication ” and “Company System”,
the team targeted on individual performance improvement and challenging spiritual company building and made renovative suggestions to the management.
One of the suggestions that has been adopted is the online proposal box for all employees.

Additional ownership acquisition by the Sponsor
In the public offering conducted in February 2022, the Sponsor acquired an additional 2,410 units of the new investment units issued by CRR.
Going forward, we expect to receive strong Sponsor support through the further aligning of our interests.

Before issuing units

Issuing units

After issuing units

Number of units issued andoutstanding

692,994

22,988715,982

Number of units held bySponsor62,2642,410

64,674

9.0%

10.5%

9.0%

Percentage of units held bySponsor18

Sustainability Policy / Promotion Framework
External Certifications / International Initiatives
Signatory to PRI(Principles for Responsible Investment)
PRI(Principles for Responsible Investment) started in 2006, advocated by former United Nations Secretary-General to join a process to develop the following 6
Principles for Responsible Investment for financial industry, and has been developed as an international investor network by UNEP (FIUN Environment Programme
Finance Initiative) and UNGC (UN Global Impact) to put these principles into practice. PRI works to understand the investment implications of environmental, socialand governance (ESG) factors, and to support its international network of investor signatories in incorporating these factors into their investment and ownershipdecisions. The asset management company announced support for these principles and joined signatory in December 2021.
＜Six Principles for Responsible Investment＞
Principle 1: We will incorporate ESG issues into investment analysis and decision-making processes.
Principle 2: We will be active owners and incorporate ESG issues into our ownership policies and practices.
Principle 3: We will seek appropriate disclosure on ESG issues by the entities in which we invest.
Principle 4: We will promote acceptance and implementation of the Principles within the investment industry.
Principle 5: We will work together to enhance our effectiveness in implementing the Principles.
Principle 6: We will each report on our activities and progress towards implementing the Principles.

Participate in GRESB Membership
The asset management company has well recognized the importance of environmental, social and governance (ESG)
factors in investment and asset management, joined GRESB membership(GRESB Real Estate/ Company & Fund Manager
Member) in February 2019.
As an International Initiative member, the asset management company has been conducting sustainability initiatives
through network with pioneer company, related information collection and GRESB Real Estate rating, etc.

GRESB Real Estate Assessment
CRR has been participated in the GRESB Real Estate Assessment since 2018.
We will continue to promote sustainability initiatives through the participation and aim to further improve its rating in
the assessment.

19

Sustainability Policy / Promotion Framework

Signatory to UNGC(UN Global Impact)
UNGC(UN Global Impact) is a voluntary global corporate sustainability initiative joined by corporate andbodies taking responsible and innovative leadership to seek sustainable growth.
UNGC advocates corporate participant to align strategies and operations with 10 universal principles onhuman rights, labor, environment and anti-corruption and take actions that advance societal goals throughactive engagement.
TFHD has been a signatory to the United Nations Global Compact since December 2016 and TRM
supports the UNGCʼs 10 principles as a member of TFHD Group.（For the UNGC 10 principles, pleaserefer to page 48.)
TRM shares the Human Rights Policy of TFHD Group announced in January 2020 (Cf. page 47) andconducts business in belief that the respect for the human rights of all its stakeholders is essential.
We also believe that all the companies should hold such respect.

Support for TCFD (Task Force on Climate-related Financial Disclosures)
TCFD refers to the Task Force on Climate-related Financial Disclosures, established by the
Financial Stability Board (FSB) at the request of G20, to examine how climate-related
information should be disclosed, and how should financial institutions respond.
Asset Management Company has announced support for the recommendations of TCFD in
January 2021, and joined the TCFD Consortium, an organization established by domestic
companies supporting TCFD.

20

Environment

Our View on Environment
We are implementing sustainable property management
through various initiatives, including reducing energy
usage and acquiring environmental certifications.

Environment
7.3 By 2030, double the global rate of improvement in energy efficiency

Relevant SDG Targets

12.5

By 2030, substantially reduce waste generation through prevention, reduction, recycling and reuse.

12.8

By 2030, ensure that people everywhere have the relevant information and awareness for sustainable development and lifestyles in harmony with nature

Environmental Performance
Reduction targets

Actual Figures（Note1）

Among the various problems relating to the environment, CRR views climatechange as main risk, and we have specified the reduction of our environmental
footprint as a target in our materiality.
We are aiming to reduce our energy consumption by 1% per year on an intensity
basis over the medium to long term, and also reduce CO2 emissions by 40%
relative to FY2020 on an intensity basis until FY 2030. Recognizing that reducing
our environmental footprint and contributing to the mitigation of medium-to longterm climate change risks, such as extreme weather and sea level rise, will
support the maximization of medium-to long-term unitholder value, which is
CRR’s priority issue, we are striving for sustainable growth through initiatives
targeting the environment and the realization of a recycling-oriented society.
Item
Energy consumption per year
CO2 emissions per year

Reduction targets（Intensity basis）

Energy consumption（Note3）CO2 emissions（Note4）

Water consumption(Note 5)

Water consumption per year

avoid increase in intensity

Waste generation per year

avoid increase in intensity

2019

2020

2021

Actual

9,024

9,693

8,420

8,917

Intensity（Mwh/m²）

0.102

0.113

0.091

0.092

Scope 1

297

304

260

270

Scope 2

3,505

3,720

3,121

3,233

Total
（t-CO2）

3,802

4,024

3,381

3,503

Intensity（t-CO2/m²）

0.043

0.047

0.036

0.036

Actual38,23239,08940,122

29,160Intensity

0.413

0.426

0.406

0.283

（Mwh）

（t-CO2）Medium-to long-term target of 1%
average annual reduction
40% reduction by 2030 (vs.2020)

2018（t-CO2）（m³）（m³/m²）(Note1)As a rule, the actual figures for common areas of rental residences in the portfolio are indicated. Intensity is calculatedwith the following formula: total consumption for a given year ÷ floor area of common areas (in the case of water
usage, some private areas are included in the results).
(Note2) The actual figures from FY2020 were assured by a third-party organization. (Page 92)(Note3)The actual figures for fuel (gas, kerosene) and electricity consumption in common areas are indicated, but the electricity
consumption for 2018 and 2019 includes the amounts used by some retail tenants.
(Note4)CO2 emissions were calculated using the Ministry of the Environment’s “Calculation Method and Emission Coefficient
List for the Calculation, Reporting, and Disclosure System” and “Emission Coefficient List by Electricity Provider.”(Note5) Since the water consumption amounts indicated in the assurance report (Page 92) include the consumption amounts
for parts of operational rental residences, the values differ from the actual results above.
Besides, the actual figures of COMFORIA SHINOSAKA’s exclusive area are included until March 30th, 2021.
22

Environment
Approach to Climate Change
How We Look at and Approach Climate Change① Our Perception of and Basic Approach to Climate Change
We are well aware that climate change is a critical issue that has a great impact on our business activities.
The Sixth Assessment Report of the Intergovernmental Panel on Climate Change (IPCC), published in 2021, firmly concludes that humans have warmed theatmosphere, ocean, and land. The report attributes increases in greenhouse gas (GHG) concentrations including carbon dioxide since around 1750 to humanactivities such as heavy consumption of fossil fuels. At the 26th United Nations Climate Change conference (COP26) also held in 2021, participating countries
formally agreed that they will pursue efforts to limit temperature increase to 1.5℃. This agreement came amid growing awareness that limiting the increase in the
global temperature to 2℃ above levels in the Industrial Revolution--the maximum allowable level under the Paris Agreement of 2015--will not preclude tremendous
negative impacts. Given the global temperature has already risen by more than 1℃, however, we believe that achieving this target requires bold actions, including
social and structural changes.
We need to adapt to emerging waves of change generated by these increasing impacts of climate change, more solid global frameworks for climate change, andtransition to a decarbonized society. We also need to secure both stable earnings and steady growth in assets under management over a medium to long term. To
these ends, it is important for us to predict risks and opportunities that climate change may present to our business, to work with our unitholders and otherstakeholders, and to reflect such risks and opportunities in our investment strategies and property management.
TRM, the asset management company to which CRR entrusts the management of its assets, is mindful of the need for environmental and social considerations
and strong governance. And, as a member of the Tokyu Fudosan Holdings Group, the asset management company shares the Group’s Sustainability Vision.
The asset management company believes that addressing these needs constitutes part of its social responsibilities and is also an avenue to practice its
management philosophy. It also believes that doing so will contribute to development of a sustainable society. To put this belief into practice, the asset
management company has identified materiality under its Sustainability Policy and shares them with CRR. For more information on the Sustainability Policy andthe materiality, please refer to the asset management company’s Sustainability Initiatives.
The escalation of climate change has a huge impact on our efforts toward “reducing environmental impact,” one of our materiality. For this reason, we demonstrate
to our suppliers our commitment to environmentally preferable purchasing with our Green Procurement Standards, established in September 2020. We join handswith our suppliers in taking action based on mutual understanding.
To redouble its efforts to address these issues, the asset management company has signed on to the Principles for Responsible Investment (PRI), joined GRESB
as a member, and embraced the UN Global Compact (UNGC) in conducting business activities.
② Support for the TCFD Recommendation
Asset Management Company has announced support for the recommendations of TCFD in January 2021, and joined the TCFD Consortium, established bydomestic companies supporting TCFD.

23

Environment
Organizational Governance for Addressing Climate Change① Promotion System
For information on the implementation setup at The asset management company (including responses to climate change; hereinafter the same), please refer to“Promotion System” (Page 9).
② Sustainability Promotion Council
As part of its efforts to address sustainability issues, the asset management company convenes the Sustainability Promotion Council regularly to sharesustainability-related information (including responses to climate change) and discuss measures to take on these challenges and implement them. The Council also
monitors progress in our sustainability efforts regularly and continuously. For more information about the Council, please refer to “Sustainability Promotion Council”(Page 10).
③ Environment Management System
The Asset Management Company established a unique environment management system (EMS) which applies PDCA cycle to continuously approach toenvironmental challenges. We are working to continuously reduce environmental impacts in the management operation for CRR, through the cycle of four steps;
set targets (Plan), assess performance (Do), analyze budget vs. actual (Check), and implement countermeasures for a better performance (Act).
The Asset Management Department of Comforia Management Division reviews actual performances regularly, reports review findings to the management at least
once a year and receives both feedbacks for the fiscal year under review and directions for further improvement for the next fiscal year from the management.
④ Climate Action Standards
For matters related to addressing climate change, the Asset Management Company has in place a set of climate action standards, under which it has built its
structure to promote sustainability and established an action policy that builds on the TCFD framework. For information on the management of risks andopportunities related to climate change, see “Managing Risks and Opportunities Related to Climate Change”(Page 29).
⑤ Reporting on Performance
Meeting entity

Convening entity

Meeting frequency

ESG meeting at Comforia Management Division

TRM

Three times or more a year

Sustainability Promotion Council

TRM

Four times a year

TRM’s Board of Directors meeting

TRM

Once a year (reporting)

CRR’s Board of Directors meeting

CRR

As needed (reporting)24

Environment
Strategy That Factors in Risks and Opportunities Related to Climate Change① Scenario Analysis Assumptions
Climate change risks can be largely divided into transition risks and physical risks. CRR has analyzed three scenarios--1.5℃, 2℃, and 4℃ scenarios--using
future climate predictions announced by two international organizations*. These scenario analyses have used two timeframes during which we will continue to beaffected: mid-term (2030) and long-term (2050).
*International Energy Agency (IEA), World Energy Outlook 2021
UN Intergovernmental Panel on Climate Change (IPCC), The Fifth Assessment Report (AR5)Global outlook
under 4℃
scenario

GHG emissions remain high due to a lack of progress in decarbonization action, resulting in more frequent natural disasters. Actions need to be taken toaddress physical risks rather transition risks, which are outweighed by the former.
Climate, Natural
Environment

Policies, Laws &Regulations• A 4.5℃ rise in annual mean temperature in Japan from the 20th to
21st centuries• No progress in decarbonization policy from the present• More frequent violent typhoons toward the end of the 21st century• No strengthening of such systems as carbon taxes and emissions
trading as well as of energy efficiency standards for buildings• About a fourfold increase in flooding frequency in Japan by the endof the 21st century compared with the 20th century• Tighter laws and regulations on disaster prevention and reduction• Mild improvement in energy efficiency of existing properties• More frequent storm surges due to a sea level rise of 0.45–0.82 m
on global average caused by global warming

Investors, Financial
Institutions• The established practice of factoring in physicalrisks in making investment decisions despite ameasure of increase in ESG investment• Integrated or standards criteria not available
despite more diversity in green financemechanisms

CRR• Rising costs of addressing floods and localized
torrential rains• Operating losses due to cessation of operations
resulting from damage to properties caused bynatural disasters• No notable increase in construction andrefurbishment costs as demand for constructing
ZEBs and converting to ZEBs remains low• More burden on PM, BM, and AM companies due tothe need to procure emergency supplies, implement
BCP, and conduct disaster response drills

Tenants, Customers, Local
Communities• More considerations paid to the health,comfort, and safety of tenants and customers(measures to prevent heat stroke, BCP, etc.)• 3.2-fold increase in the per capita cost of air
conditioning (to 61 dollars) from the current
level due to rising mean temperatures• Closer cooperation with local communities intimes of disaster

25

Environment

Global outlook
under 2℃ and
1.5℃ scenarios

In these scenarios, GHG emissions are curbed thanks to various environmental regulations, and there are more ZEBs. Actions need to be taken to addresstransition risks rather than physical risks.

Climate, Natural
Environment

Policies, Laws &Regulations• A 1.4℃ rise in annual mean temperature in Japan from the 20th to 21st
centuries• ZEBs being the standard for new constructions• The frequency and intensity of typhoons largely unchanged from the currentlevel• A rise in the average carbon price in developed countries up to 250
dollars per tone by 2050 with the introduction of a carbon tax andemissions trading• About a twofold increase in flooding frequency in Japan by the end of 21st
century compared with the 20th century• Scale-up of environmental standards and disclosure policies associatedwith improved environmental literacy• A sea level rise of 0.26–0.55 m on global average caused by global warming

Investors, Financial
Institutions

CRR• More emphasis on regulatory complianceand environmental certification• ZEBs accounting for 100% of new constructions andmore than 85% of existing properties from 2030
onward; an increase in capital investment forachieving these targets being reflected in acquisition
costs• Higher procurement costs for properties
with low environmental or fire-resistantperformance as investors consider ESG in
making decisions and environmentallycertified properties constitute a larger
percentage of the investment portfolio• Performance in addressing environmental
impacts required as an essential appraisal
criterion with green finance mechanisms inplace• A reduction of 40% in energy use from comparedwith 2020 due to more ZEBs, resulting in lower
utilities expenses• Additional operating expenses for complying withstricter laws and regulations, demonstrating
environmental actions to stakeholders, andimproving disclosures• Lower income from rentals of properties with low
environmental or fire-resistant performance

Tenants, Customers,
Local Communities• Tenants’ preference for properties withhigh environmental or fire-resistantperformance; lower demand for those withlow environmental or fire-resistantperformance• Only 1.8-fold increase in the per capita
cost of air conditioning (to 35 dollars) fromthe current level despite rising mean
temperatures• Communication with local communities
about disaster response playing a key role

• More work to comply with stricter laws andregulations at PM, BM, and AM companies

26

Environment② Analytical Procedure
The analysis of the 4℃ scenario, which assumes a world in which physical risks need to be addressed more than transition risks, has involved identifying andanalyzing long-term (2050) risks, which outweigh mid-term (2030) risks. The analysis of the 2℃ and 1.5℃ scenarios, which assumes a world in which transition risks
need to be addressed more than physical risks, has involved identifying and analyzing both mid-term (2030) and long-term (2050) risks and opportunities for eachscenario. In both analyses, financial impacts have been analyzed and assessed both quantitatively and qualitatively.
The analyses, both qualitative and quantitative in nature, have been conducted in light of the status of CRR's asset holdings, with reference made to currently
available scenarios as published by the IEA and the IPCC and to objective projections published by other third-party specialized institutions. The impact assessments
thus made assume some risk factors and their uncertainties; therefore, they do not guarantee their accuracy or safety that they may suggest.
Financial Impact
Risk
Category

Type

Item

Description of risks and opportunities

Category

4℃
2050

2050

2030

2050

Risk

Minor

Minor

Minor

Minor

Opportunity

Minor

Minor

Minor

Minor

Increased construction costs arising from compliance with ZEBrelated and other environmental regulations

Risk

Minor

Major

Minor

Major

Increased verification costs arising from compliance with ZEB-related
and other environmental regulations

Risk

Minor

Minor

Minor

Minor

Opportunity

Minor

Minor

Minor

Minor

Risk

Moderate

Major

Major

Major

Opportunity

Minor

Minor

Minor

Minor

Higher vacancy of properties with lower environmental performance

Risk

Minor

Minor

Minor

Minor

Lower demand due to little shift to properties with higher fireresistance

Risk

Minor

Minor

Minor

Minor

Shift to high-efficiency properties

Securing competitive edge by shifting to properties with higher
environmental performance

Opportunity

Major

Major

Major

Major

Increased stakeholder concern
or negative stakeholder
feedback

Divestment or poor access to capital markets

Risk

Minor

Minor

Minor

Minor

Changing customer behavior

Lower demand due to little shift to properties with higher fireresistance

Risk

Minor

Minor

Minor

Minor

Policies,
Laws &
Regulations

Mandates on and regulation ofexisting products and services

Cost arising from carbon tax levy
Higher efficiency due to shift to properties with higher eco
performance

Higher efficiency due to shift to properties with higher eco
performance

Technology

Substitution of existing products
and services with lower
emissions options

Changing customer behavior
MarketReputation

1.5℃

2030

Increased pricing of GHG
emissions

Transition
Risks

2℃

Increased costs arising from introduction of new technologies
Higher efficiency due to shift to properties with higher eco
performance

Note: Risks are represented in orange and opportunities in blue. The scale of the financial impact (minor, moderate, major) is expressed by the depth of color: the deeper the color is, the larger the impact is.

27

Environment

Financial Impact
Risk
Category

Type

Item

Description of risks and opportunities

Category

4℃
2050

Acute

Increased severity of extreme weather
eventsPhysical
Risks

Chronic

Rising mean temperatures and sea
levelsCosts incurred from the need to address torrential rain disasters, etc.

Risk

Major

Loss of sales opportunities due to torrential rain disasters, etc.

Risk

Minor

Increased costs of air conditioning due to rising temperatures

Risk

Minor

Inundation due to sea level rise

Risk

Minor

2℃
2030

1.5℃
2050

2030

2050

Note: Risks are represented in orange and opportunities in blue. The scale of the financial impact (minor, moderate, major) is expressed by the depth of color: the deeper the color is, the larger the impact is.

③ Analysis Findings
Both the 2℃ and 1.5℃ scenarios entail substantial transition risks. In these two scenarios, the introduction of a high carbon tax designed to curb CO2 emissions
in Japan is likely to mean higher operational costs stemming from, for example, a heavier tax burden on CO2 emissions from proprietary properties. Stricter
environmental regulations with regard to ZEBs, energy saving standards, and the like are likely to translate into additional costs of refurbishments needed tocomply with them.
Tighter regulations will have a tremendous impact on tenants’ choice of properties. It is expected that in comparing properties of different real estate agencies,
demand for properties with lower energy efficiency will decline.
With an eye on a transition to a decarbonized society under the scenarios of under 2℃, CRR is committed to addressing these risks and maintaining its
competitive edge. To these ends, CRR will take a number of actions. These include implementing energy efficiency retrofits, a typical example of which is asystematic switch-over to LED lighting in the communal areas; increasing the proportion of environmentally certified properties; and incorporating green-leaseprovisions in contracts with new tenants.
Under the 4℃ scenario in which little progress will be made in decarbonization, CRR expects damage to its proprietary properties due to increased severity of
extreme weather events and resultant increases in repair expenses. With regard to chronic changes such as rising mean temperatures, CRR is committed toreducing CO2 emissions by, for example, considering and replacing existing key equipment such as electric and air conditioning equipment with more energyefficient equipment wherever possible when it reaches its end of life.

28

Environment
Managing Risks and Opportunities Related to Climate Change
Matters related to materialities regarding climate-related risks and opportunities and adaptation and resilience to climate change are regarded by the AssetManagement Company as matters related to climate action in accordance with its climate action standards. They also constitute specific sustainability initiatives
and are therefore part of the matters related to promoting sustainability.
In January 2022, we announced our support for the TCFD Recommendations, which prompted us to conduct scenario analyses described above. The analyses
were aimed at identifying risks and opportunities arising from the impact climate change may have on CRR, assessing the impacts of these risks and opportunities
on our business, and making changes to our future strategies as needed. Risks of particular importance were singled out in light of how likely they emerge, when
they emerge if ever, and how they may impact our finances.
Based on the analysis findings, we will improve on our initiatives. To this end, we will execute function management with the help the EMS and monitor CRR's
actions and their progress through the Sustainability Promotion Council.

Setting Metrics and Targets Related to Climate Change① Metrics and Targets
CRR has identified its metrics and targets related to climate change under the category of "reducing environmental impact," one of the materialities it shares with
the Asset Management Company. For the purposes of identification, CRR assessed risks and opportunities presented by the impacts of climate change as well as
the importance of specific actions aimed at addressing these impacts. CRR has also set out a policy for reducing environmental impact. The policy covers four key
areas: energy use, energy-related CO2 emissions, water conservation, and waste generation. Additionally, CRR has been stepping up efforts to improve energy
efficiency under the following targets it has set for climate action. Specific actions to this end include implementing energy efficiency retrofits and incorporating
green-lease provisions in tenant contracts.

 Energy use: Medium- to long-term target of 1% average annual reduction in energy use intensity
 Energy-related CO2 emissions: by 2030, 40% reduction in greenhouse gas emissions intensity (vs.2020).

② Progress toward Targets as Well as Practices
CRR regularly discloses information on environmental performance with regard to energy consumption, CO2 emissions, and water consumption, as well as
Environmental Certification and environmental impact reducing works. It also provides relevant information on the annual Sustainability Report and financial
statements as part of ESG-related information.

29

Environment
Environmental Considerations
Switching to LED lights in common areas

Replacing air conditioners in private areas

For environmental conservation, CRR has been switching to LED lights in the common
areas of properties. This will help reduce power consumption and environmental impact.

For environmental conservation, CRR has been replacing air
conditioners that have reached a certain number of years since
installation in the private areas of properties. This will help reduce
power consumption and environmental impact.

Installation of electric power measuring system

Green-lease provisions

In order to increase the actual electric power
consumption coverage rate at owned
properties, electric power measuring systems
have been installed at 2 properties as of theend of July 2022. The installation makes it
possible to measure power consumption at
exclusive areas. Furthermore, activities toraise awareness for energy saving among
tenants are being carried out.

From the perspective of environmental friendliness, to reduce environmentalload in collaboration with residents, we insert green-lease provisions in leaseagreements, which are related to energy use and appropriate disposal of waste.

Green Procurement Standards
CRR will promote the reduction of the environmental load in cooperation with
suppliers, etc. by establishing the Green Procurement Standards which are
related to the procurement of environment-friendly materials, etc. (Cf. page 55)

30

Environment
Considerations for recycling-oriented society
Separate management of waste

Use of Renewable Energy
CRR utilizes renewable energy fromsolar power

CRR reduces environmental impact at
properties through separate disposal ofwaste in cooperation with the managementcompany. It is also making effort to improveresident satisfaction by taking measures toreduce odor at garbage collection points.

Annual power generation of the solar power
facilities in COMFORIA NAKAOCHIAI

4,199.7kwh（Feb.2021～Jan.2022）

Providing garbage disposal guides
For environmental conservation,
COMFORIA SHINJUKU EASTSIDETOWER offers guidance on separate
disposal of garbage in the user guides forresidents to raise environmental
awareness.

Sponsor’s Renewable Energy Business
Our Sponsor Tokyu Land Corporation started environment-friendly renewableenergy business in 2014 by utilizing long-amassed expertise in community
planning and partner co-creation as a comprehensive developer. Participating inRE100(note) as the first real estate company in 2019, TLC have reset 2022 as thetarget year for achieving RE100, or use of electricity from 100% renewableenergy for corporate activities, accelerating the speed from expected FY2025.
Note: RE100 is the global corporate renewable energy initiative bringing together hundreds of large and ambitious
businesses committed to 100% renewable electricity.

Electricity Saving Actions in Common Space & Facilities
In order to save common area’s electricity
power, we have cooperated with property
management company to conduct airconditioner temperature change andturned down the common area’s lights insome of the properties.
We have been making efforts to advocateenergy efficiency to the tenants .

ReENE Matsumae Wind Power Plant

ReENE Namegata Solar Power Plant

31

Environment
Considerations for recycling-oriented society
Recyclable Materials Widely used

Increasing Greenery and Biodiversity
With a site area of more than 1,000
square meters, Comforia Shinjuku
Eastside Tower has developed a greening
plan in accordance with the Ordinance for
the Conservation and Restoration of
Nature in Tokyo, based on which it offers
a lush space filled with natural features.

Environment-friendly/Energy-efficiency
construction materials/facilities Lists
have been made and used in bid
specifications for Large-scale repair
work. For example, recyclable tile
carpet has been adopted in common
area to reduce industrial waste andincrease resource usage efficiency.

Reuse Event

Compost Trial

Asset management Company puts the3R(Reduce, Reuse, Recycle) principles
based on Green Procurement
Standards into practice such as thereuse event, in which the employee
voluntarily share the unused or low
usage frequency goods with each other.
A chance to advocate environmentalfriendly actions and internal
communications between employees.

In Campus Village Urayasu, thekitchen waste and food scraps inthe cafeteria are collected and put
into the soil bag as compost.
Interior gardening trial has started

At COMFORIA KINSHICHO DEUX, wehave alleviated the heat island effect andimplemented energy-saving measures byplanting vegetation on the rooftop.

Efficient use of water
We comprehend owned properties’equipment using water and their function
and consider introducing water-saving
equipment at properties that have yet toemploy said equipment where possible.
We promote efficient use of water
resources by changing to products thatsave hot/cold water.
32

Environment
Establishment the Environment Management System(EMS)TRM established a unique environment management system (EMS) which applies PDCA cycle to continuously approach to environmental challenges. We areworking to continuously reduce environmental impacts in the management operation for CRR, through the cycle of four steps; set targets (Plan), assess
performance (Do), analyze budget vs. actual (Check), and implement countermeasures for a better performance (Act). The Asset Management Department of
Comforia Management Division reviews actual performances in its monthly meeting and reports the results to the management at least once a year, then receives
feedbacks and instructions for further improvement for the following year, from the management.

33

Environment
Urban Site Investment Criteria
Undeveloped Sites Commitment

Investments Towards Urban Revitalization
and Redevelopment Properties

CRR aims to secure stable income and achieve steady growth of our assets
under management from a medium-to long-term perspective. When acquiring
assets developed on undeveloped sites, we give ample, rigorous consideration
to the impact that development activities have on the natural environment andecosystems, as well as considering compliance with environmental laws, theacquisition of environmental certifications, etc. before investing in them.

As a rule, CRR does not invest in unoccupied properties that have not been
completed yet, such as new development projects, but we actively invest inproperties developed based on redevelopment projects. Through theacquisition of such properties, we contribute to the revitalization ofcommunities by improving convenience for local residents.

Investments in Flexible / Mixed Use Properties

COMFORIA SHINJUKU EASTSIDE TOWER

CRR owns a number of mixed-use properties. By investing in mixed-use
properties that house facilities such as convenience stories and clinics, we
contribute to improving the convenience of daily living for tenants and nearby
residents, reducing the environmental footprint by reducing the travel distance
between various facilities, and the revitalization of communities.

Investments Towards
Existing Urban Brownfield Redevelopment
COMFORIA SHIBUYA WEST

COMFORIA SETAGAYAKAMIUMACOMFORIA HIGASHISHINJUKUSTATION FRONT

Environment Risk Assessment for New Acquisition
CRR makes investment decisions based on its investment strategies and theresults of due diligence, including onsite investigation, property materials
scrutinization, valuation appraisal report, engineering report, land contamination
investigation report, etc.

Through investing in existing development areas, especially in Tokyo’s 23 wards,
CRR invests in properties that utilize existing infrastructure, such as roads, waterand sewer lines, schools, and hospitals.
By making use of existing infrastructure, we are engaged in investment thatprevents urban sprawl and leads to a decrease in energy consumption
associated with shipping/traffic and the loss of green areas, which causes theheat island effect.
34

Environment
Green Building Certification

Believing that establishing a portfolio with a small environmental footprint will result in improved unitholder value in the medium-to long-term , CRR has targeted theacquisition 40% of environmental certifications by FY2030.
Aim to obtain environmental certification

Performance（as of the end of Jul. 2022）

40% by FY2030

6 properties・20.1％（based on gross floor area)）

DBJ Green Building Certification
DBJ Green Building Certification Program was launched by Development Bank of Japan Inc. (DBJ) for the purpose of supporting the properties which give propercare to environment and society (Green Building).The program evaluates, certifies and supports properties which are required by society and economy. It makes
comprehensive assessment of properties, while evaluating various factors which range from properties' environmental features to their communication withstakeholders, such as disaster prevention and proper care for surrounding communities.
Furthermore, there are 5 levels, "five stars", "four stars", "three stars", "two stars", "one star" as the certification ranks.
CRR has acquired the DBJ Green Building Certification for the following property.

Five Stars

COMFORIA SHINJUKU EASTSIDE TOWER

Four Stars

COMFORIA TOYOCHOCOMFORIA SHIBUYA WEST

COMFORIA KAMATACOMFORIA HIGASHISHINJUKUSTATION FRONT

35

Environment
Green Building Certification
CRR has been making progress in the green building certifications.
Comforia Shinjuku Eastside Tower was the first residential REIT property to obtain the “S rank” of CASBEE Certification for Real Estate in December 2021.
Consecutively, Comforia Omiya also obtained the “S rank” in July 2022.

CASBEE Certification for Real Estate
CASBEE is an evaluation system for rating the environmental performance of buildings, developed under the auspices of the Ministry of Land, Infrastructure,
Transport and Tourism. The system rates the overall environmental performance of buildings from the following perspectives: the evaluation of the environmental
quality and performance of buildings themselves and the external environmental load of buildings.
Certification for CASBEE for Real Estate is rated in four scales: rank S, rank A, rank B+ and rank B for buildings with over 1 year after completion.

COMFORIA SHINJUKU EASTSIDE TOWERCOMFORIA OMIYA

36

Environment
Green Bonds
As part of its efforts to contribute to the development of sustainable society, CRR has issued the Green Bonds. CRR aims to further promote its sustainability initiatives through issuance of the green
bonds, and invite new investors to its investment corporation bonds by stimulating their demand who have interest in ESG investment.

Green bond Framework
1．Use of Proceeds
The proceeds of the green bond will be allocated to acquire the existing or new buildings that meetthe following Eligibility Criteria A (‘Eligible Green Projects’), or refurbishments that meet the following
Eligibility Criteria B or to refinance the existing loan/investment corporation bonds which have been
allocated to Eligible Green Projects or refurbishments.

2．Eligibility Criteria

3．Management of Proceeds
CRR extracts the Eligible Green Projects out of CRR’s portfolio and uses the calculable total bookvalue of the Eligible Green Projects as of the end of the latest fiscal period prior to the date of eachbond issuance (note 1) as the Debts of Eligible Green Projects. As long as the Green Bond isoutstanding, we will monitor once a year, to ensure that the total amount of outstanding green bonds
does not exceed the sum of Debts of Eligible Green Projects and green bond proceeds allocated torefurbishments.

CRR shall apply one or more of the following criteria to allocate the proceeds into Eligible Projects:

As of July 31, 2022

A. Eligible Green Projects
Buildings that have achieved the following top three levels of third-party green building
certification/recertification within 36 months prior to the payment date of green bonds or willachieve:① B+, A or S Rank under CASBEE② 3, 4 or 5 Stars under DBJ Green Building Certification Program③ 3, 4 or 5 Stars under BELS

B. Refurbishments
Refurbishments with a primary purpose of achieving one of the following criteria and arecompleted within 36 months prior to the payment date of green bond or will be completed:① Refurbishments with more than 20% reduction in energy consumption and water consumption② Newly achieve the top three levels of green building certifications listed above Eligibility
Criteria A or more than one level of star/rank improvement in the green building certification(Note1) “Eligible Green Projects as of the end of the latest fiscal period to the date of each bond issuance” refers to the buildings that haveachieved the top three levels of one or more of the third-party green building certifications/recertifications within 36 months prior to the endof the financial period immediately preceding each date of bond issuance.
(Note2)The amount of Eligible Green Projects is calculated based on the book value at the end of July 2022.
(Note3)Outstanding amount of the green bonds is calculated as of July 31, 2022.

37

Environment
4．Reporting
CRR will disclose on its website the amount of Eligible Green Projects and/or refurbishments financed/refinanced, allocation status, including the amount of unallocated proceeds, schedule of allocation andmanaging method, of the net proceeds of green bonds as of end of every January until the proceeds are fully allocated. In the event of major change in situation, such as the accrual of unallocated funds as aresult of the sale of relevant assets, such facts will be disclosed in a timely manner. CRR will also disclose that the total amount of outstanding green bonds does not exceed the sum of Debts of Eligible Green
Projects and green bond proceeds allocated to refurbishments. Furthermore, after issuance, for as long as the green bonds are outstanding, it will annually report on the book value of all the Eligible Green
Projects and the total amount of outstanding amount of the green bonds as of the last day of January in each year.

5．Impact Reporting
As long as there is an unredeemed balance of the relevant green bonds, CRR will annually disclose on its website summary and the progress and levels of certifications of Eligible Green Projects. Additionally,
CRR will annually disclose the following indicators of Eligible Green Projects where CRR has energy control authority:① Energy consumption② Water consumption
As for the refurbishments that have been funded by the green bonds, the environmental benefits brought by each project will be disclosed. CRR will indicate an estimated rate of reduction (%) of energy
consumption and water usage before and after the refurbishment.

Impact Reporting

Green Bond Summary
Total issue
amount Interest rate(￥million)
The 8th unsecured investment
corporation bonds(green bonds)

1,500

0.550%

Offering date

Redemption date

Description

July 30, 2020

July 30, 2030

Unsecurednonguaranteed

The 10th unsecured investment
corporation bonds(green bonds)

3,000

0.460%

July 8, 2021

July 8, 2031

Unsecurednonguaranteed

Total

4,500

－

－

－

－

Energy consumption per year
（kWh/㎡）

Water consumption per year
（㎥/㎡）

2019

41.68

0.2503

2020

38.48

0.2083

2021

39.77

0.2175(Note) Results in the above table are actual figures for the common areas in the Eligible Green Projects of CRR.

List of CRR's Green Eligible Projects

Received ranks
Property no.

Property name

DBJ Green
Building
Certification

Certification for
CASBEE for Real
Estate

BELS
Certification

Book value atthe end of
the period(¥ million)

98

COMFORIA SHINJUKU EASTSIDE TOWER★★★★★

S Rank－11,790107

COMFORIA KAMATA

★★★★

－

－

5,676

125

COMFORIA SHIBUYA WEST

★★★★

－

－

5,435

135

COMFORIA HIGASHISHINJUKU STATION FRONT

★★★★

－

－

5,635

145

COMFORIA TOYOCHO

★★★★

－

－

3,756

150

COMFORIA OMIYA-S RankTotal Eligible Green Projects

4,581
36,875（Note1）Listed are the buildings that have achieved the top three levels of one or more of the third-party green building certifications/recertifications within 36 months prior to July 31, 2022.
（Note2）“Book value at the end of the period” is calculated based on the book value at the end of July 2022. The book value of COMFORIA SHINJUKU EASTSIDE TOWER is calculated based on the Green-qualified portion of the total assets.

38

Society

Our View on Society
We are continuously maximizing unitholder value andfulfilling our social responsibilities through efforts tobuild favorable relationships between CRR and its
stakeholders.

Society

Relevant SDG Targets

11.3 By 2030, enhance inclusive and sustainable urbanization and capacity for participatory, integrated and sustainable human settlement planningand management in all countries
12.8 By 2030, ensure that people everywhere have the relevant information and awareness for sustainable development and lifestyles inharmony with nature

Stakeholder Engagement

In the pursuit of CRR’s and TRM’s business, our relationships with investors and various other stakeholders, including employees, local communities, tenants, andsuppliers, are absolutely vital. We also recognize that building favorable relations with these stakeholders in the medium-to long-term is an essential factor in our aim
of maximizing unitholder value, which is CRR’s priority. We will continue to pursue our business as a member of society and work to further strengthen our
relationships of trust with all stakeholders involved with CRR’s and TRM’s activities.

Investors◆Financial result briefing・Unitholders’ meeting◆Meetings with domestic andforeign institutional investors◆Seminar for Individual Investors◆Presentation Video

Suppliers◆Joint seminars◆Local staff awards◆各種研修制度◆人事制度
Employees◆働き方改革◆福利厚生◆ダイバーシティ◆Various
Training programs◆Work-Life Balance◆Diversity

CRR
TRM

Local Communities◆Disaster prevention
measures◆Participation incommunity activities◆Security maintenance

Tenants◆Tenant satisfaction survey◆Cooperation with tenants◆テナント満足度調査◆Effort to advance health/wellness◆テナントとの協同促進◆Disaster prevention measures◆健康・快適性向上への取組み
◆防災対策

40

Society
Employee Engagement
As a group of experts in real estate management, TRM provides high-quality asset management services with objective to maximize the value of its shareholders, andto that ends, we promote our own human-capital strategy in view of the importance of human capital development. TRM is making continuous effort to have various
systems to form a working environment and organization enabling to realize and promote the health and comfort of employees.

Strategy of Human capital development & retention
 Employee skill development（Utilization of external training institutions）
As a professional group involved in real estate management, TRM aims to maintain the quality of its services and further develop its operations. We promote and support theacquisition of specialized qualifications by our employees, and throughout the year, on a voluntary and planned basis, We hold training and seminars to share practical knowledge andindustry trends or adapt to laws and regulations and implements a range of position-based training programs and personal development activities.
≫ Training program examples（Representative efforts）

Position-based
trainings≫ Support for acquiring business related qualifications

Examples include orientation training for mid-career hires on wide
range of knowledge on asset management business andunderstanding of regulatory compliance; management training forsenior management and medium level employees; business skills
training and anti-harassment seminar for all employees withutilizing of external training institutions.
As part of awareness program on ESG investment, we invite
external experts to provide employees with periodic training fortheir deeper understanding of ESG and introduction to new
trends.

ESG training

Courses to improve computer skill, English conversation and other lessons are also provided.
≫ Training attendance record

Item

We support acquisition of necessary qualifications by employees in various measures
including financial aid for examination fees and class fees. We also hand in monetary
reward once employees pass specified examinations.
Status of employee qualification（As of June 30, 2022）
Number of
employees

Use of Qualification
Support System

Real Estate Broker

90

9

ARES Certified Master

67

23

Certified Building Administrator

18-

Certified Property Manager

14

4Chartered Member of the Securities
Analysts Association of Japan

2－

Real Estate Consulting Master3－

Qualification(FY202）

FY2020

FY2021

Training hours per employee

27.3hours

26.5hours

Real Estate Appraiser

7－

Training expenses per employee¥44,906¥89,736First-Class Architect

7

1
41

Society
 Training programs of Sponsor
The Sponsor offers HR training programs that enable each employee to exercise and develop their skills.

Desired human resources image

Position-based trainings
・Training of New employee introduction

New employee

・Joint training of TFHD Group New employees
・Training of Accounting
・Training of Critical Thinking

Employee class（New employee 〜
Ninth year employee）

・Self-management
・Enhancement of organizational strength・Expansion of self-capacity

Second year
employee

Third year
employee
Fourth year
employee

・Training of Communication
・Training of Finance・Training of Negotiation
・Training of Facilitation
・Training of Strategy/Marketing
・Training of Legal/Compliance・Strategy・Marketing（Advanced）・Assessment

Chief classManagement class・Training of Hypothesis Thinking

・Leader-ship skill
・Management skill
・Expansion of self-capacity

・Training of New Group-leader
・Training of New Group-leader Coaching・Training of Executive Manager
・Digital Transformation（Note）Employees temporarily assigned to TRM from the Sponsor are included in the above training.

 Personnel system
TRM has regular communication opportunities with employees including one-on-one session with the direct supervisor and review staffʼs performance based on the objective ofcareer development set by each. We encourage each staff to have their own career plan and to acquire skills that are competent inside and outside of the company. ESG-related
efforts and relevant items are included in the annual target to set. Based upon the fact that the number of employees of TRM had increased to a certain size, partly because of themerger happened in 2017, we decided to conduct shuffling of employees among different divisions in order to raise career development of our employees. Meanwhile when
conducting such occupational relocation, we pay close attention to the information firewall between the different business divisions.

42Society Personnel System
The asset management company conduct regular communication with employees by one-on-one meeting between employees and their direct supervisors andperformance review based on individual career development objective setting and realization conditions. Each personnel is encouraged to have their own careerplan and to acquire skills that are competitive both inside and outside of the company. ESG-related target are also required to be set in the annual targets.
 Human Resource Exchange
The asset company takes staff seconded from the sponsor group companies and dispatcher its employees to the sponsor group to provide the employees withvarious professional experiences. As the number of employees increased to a certain size, partly due to the merger in 2017, employees shuffling among different
divisions are also allowed for the purpose of career development. And when such position relocation happened, we pay close attention to the information firewall
between different business divisions.
 Recruitment website
In December 2021, asset management company launched a career page to attract potential candidates by comprehensively presenting the company’s business,characteristics, and cultures, etc. The website contents include interviews with current employees, round-table talk, career path possibly realized in the company.
(Recruitment page: https://www.tokyu-trm.co.jp/recruitinformation/）43

Society
For work-life balance & health of employees Working-style reform

Recently, under the working-style reform trend including rectifying the practice of working long hours, TRM actively takes approaches to introduce more flexible working style ofemployees with objective to improve their work-life balance.
Paid-leave usage encouragement

Every year, employees are required to set up so-called “commitment holidays”, a seven-day paid leave (five days in a row + two days
immediately before or after that week) and to share such committed calendar within the teams they belong to. TRM is also creating
business environment for the employees to digest their allocated paid leaves, by proactively setting up recommended days to use paid
leaves.

Flex-time work system

We have introduced a flex time working system for all employees. Core time is set between 11:00 and 15:00, and employees are free toset start and finish of their work hours around the core time to support more flexible working style considering the wide variety of living
environment of each individual.

Work-from-home system

The Covid-19 outbreak pulled the need for introduction of work-from-home, and we are working to improve productivity with reducing
commuting time to workplace. Use of serviced office space is also allowed under preset rules.

Effort to reduce overtime

In order to prevent excessive long working hours, TRM is taking necessary measures. The employees are required to set an upper limitof overtime working hours at the beginning of the fiscal year, and such objectives are regularly monitored and reminded. In certain
cases, we intentionally raise them as a meeting agenda if the working hours are excessively long.

 Welfare programs

TRM values its employees, their well-beings, and healthy performance in work, and provides all staff with various welfare programs to improve their satisfaction as below.
（Excludes contract/dispatched employees for some Welfare programs）
Cafeteria plan

To support self-support and independence of permanent employees, we provide them with financial aid for medical fees, subsidies for use of
sports facilities, studying, volunteer activities, employee shareholding program, and use of the facilities Tokyu group companies operate.
Various systems are in place to provide support for employees at each stage of life, such as maternity leaves, childcare leaves, child medical
leave, nursing-care leave.
We support asset formation by permanent employees, by inviting external financial planners to offer introductory sessions on topics including
defined contribution pension matching program which TRM offers and the insurance system by the Tokyu group.
Through our employee stock ownership plan and cumulative REIT investment program, we provide financial incentives for purchasing fixedamounts of TFHDs stock, Comforia Residential REIT investment units, and Activia Properties investment units.

Welfare programs

We increased the number of available facilities to enable more employees to use the popular exclusive resort membership “Tokyu Harvest Club.”44

Society
 Internal communication
TRM periodically organizes employee satisfaction surveys and explanatory sessions on the corporate annual objective and medium- to long-term vision, for a more profoundunderstanding between the company and employees, expecting to develop the productivity of our organization where employees can deliver their best performance.
Employee study groups

Younger employees have led voluntary organization of cross-divisional study groups to share information on businesses unique to each division,and on necessary knowledge/skills.

Support for company circle
activities

Financial support is provided to employees for company club activities.

Luncheon

To enhance communication among employees, regular luncheons by groups of a small number of staff have been organized.

 Employee health & comfort

TRM is making effort to maintain the workplace healthy and comfortable, encouraging employees to show the best performance.
Workplace of TRM is in Shibuya, an exciting and innovative city where the areas people live and play are closely connected. Employees can takebeverages for free and use individual spaces, and a space for refreshment is created with green on the terrace of the building where TRM is
located, Shibuya SOLASTA. The building earned the CASBEE Wellness Office, a recognition of the buildingʼs ability to promote health and comfortof people work in the building.

Working environment
Also, as a preventive measure against COVID-19, the workspace of TRM is equipped with protective panels on the desks in office space andmeeting rooms, as well as air purifiers at the elevators.

Healthcare

Employees are obliged to take annual medical checkups. There is also a mental health consultation desk.

Health Committee

Health Committee is established to improve employeesʼ occupational health. The Committee examines labor-related problems occurred in thecompany, reports the results of investigation on comfort and safety in the workspace, and takes measures to increase awareness for mental andphysical health by poster, etc. Lectures by industrial physicians on related themes are held.

Once a year, employees have one-on-one session with HR department, where they can discuss and share their career development plan and
One-on-one session with HR explain their troubles and expectations related to the relationship with supervisors and colleagues. The confidentiality of employee information is
guaranteed.

Whistleblower system

TRM established the Compliance Helpline Counter as a contact point to report and consult on compliance matters including when harassment andbullying is experienced or observed, enabling all officers and employees to directly report to the Compliance Officer of TRM, General Manager ofLegal Affairs Department of TLC, General Manager of Group Legal Affairs Department of TFHD, or external attorneys. Moreover, we pledge tomaintain the confidentiality of personal information or investigation-related information about the individual who reported or consulted on the matterand the subject of the report or consultation, which shall not be disclosed internally or externally without good reason.
45

Society
 Employee satisfaction survey（Survey with a third-party）
Every year, TRM conducts an employee satisfaction survey with a third-party partner. Based upon the results of the survey, we are taking variety of means to improve employee
satisfaction level.
Item

FY2019FY2020

FY2021

Employee engagement level

62.6

60.8(Note)

62.8

Nb. of responses / Nb. of eligible employees

95 / 95

96 / 98

100/100

Participation rate

100%

98%

100%

(Note) The figures are in high level among Japanese companies, and the engagement status is overall good.

 New Work Style Project
A voluntary team set up by asset management company employees launched a new project in October 2021, aiming to design and propose new work styles. Mainly
concentrated on 3 Topics as “office and digital environment’’ “internal Communication ” and “Company System”,
the team targeted on individual performance improvement and challenging spiritual company building and made renovative suggestions to the management.
One of the suggestions that has been adopted is the online proposal box for all employees.

46

Society
SocietySociety
Diversity
TFHD Group accepts the difference in a variety of attributes such as gender, age, nationality and handicap and brings about innovation by showing individual ability to the maximum
and continues to create value through its business activities. TRM is working to make a workplace without any discriminatory treatment and compensation due to different attributes,
where all employees can rely on.

 Human Right Policy
TRM shares the Human Right Policy published in January 2020 by TFHD Group and carries out
its business in belief that respect the human rights of stakeholders of the group including
employees is essential and it is what all companies are expected to do.
TFHD Group Human Rights Policy

47

Society
Respecting basic labor rights and aiming at coexistence and co-prosperity with employees, TFHD Group supports and respects the OECD Guidelines for Multinational Enterprises,
international labor standards and Guiding Principles on Business and Human Rights. In December 2016, the Group stated its support for the UN Global Compact. In accordance withthe ten principles of the UN Global Compact in the areas of human rights, labor, environment and anti-corruption, we promote responsible management and contribute to a sustainable
society. TFHD Groupʼs support for UN Global Compact shall apply to all group companies including TRM

The 10 Principles of the UN Global Compact

Fundamental rights in hiring and employment of TFHD GroupTFHD Group will respect the following matters as a set of fundamental rights in hiring andemployment in order to achieve co-existence and co-prosperity with employees
1.Prohibition of discrimination: We will eliminate all discriminatory actions based on nationality,
race, religion, beliefs, gender, age, sexual orientation and/or disability and will strive to maintainequal opportunity and treatment in hiring and employment.
2.Prohibition of harassment: We will never engage in sexual harassment, power harassment, or
any other form of harassment toward people in the workplace. We will also never tolerate
language or actions related to harassment.
3.Prevention of forced labor: We will strive to eliminate and prevent all forms of forced labor.
4.Curtailment of overwork and reduction of overtime: We will establish a fundamental policy on
work management to curtail overwork and reduce overtime work giving consideration toemployees’ work-life balance and their health maintenance/improvement. In Japan, we willcomply with the “Article 36 Agreement.”
5.Prevention of child labor: We will support and practice the effective abolishment of child labor.
6.Respect for freedom of association and the right to collective bargaining: In recognizing thatthe freedom of association and the right to collective bargaining are fundamental human rightsthat must be respected by a company, in countries and regions where the formation of labor
unions is allowed we fully recognize employees’ right to organize, right to collective bargaining
and right to strike in labor agreements. In addition, even in countries and regions that do notallow the formation of labor unions due to laws or practice, we will effectively promote conflict
resolution through dialogue involving management and labor with the purpose of securing thefreedom of association and the right to collective bargaining.
7.Payment of wages above and beyond the minimum wage: We will comply with labor laws andregulations and adopt a fundamental policy on labor management in which we will pay wages to
employees above and beyond the minimum wage for acceptable living conditions.

Human rights

Principle 1: Businesses should support and respect the protection ofinternationally proclaimed human rights; andPrinciple 2: make sure that they are not complicit in human rights abusesLabourPrinciple 3: Businesses should uphold the freedom of association andthe effective recognition of the right to collective bargaining
Principle 4: the elimination of all forms of forced and compulsory labour:
Principle 5: the effective abolition of child labour; andPrinciple 6: the elimination of discrimination in respect of employment andoccupation

Environment

Principle 7: Businesses should support a precautionary approach toenvironmental challenges;
Principle 8: undertake initiatives to promote greater environmental
responsibility; andPrinciple 9: encourage the development and diffusion of environmentallyfriendly technologies

Anticorruption

Principle 10: Businesses should work against all forms of corruption,
including extortion and bribery48

Society
Key Employee Data
Item
Number of Employees（Note1）
Male
FemaleOf which full-time
MaleFemaleOf which contract employees
MaleFemaleOf which contract employees from convert
temporary employees
Of which seconded（Note3）
Male
FemaleRatio of female employees(Reference)Temporary employees
MaleFemaleNew Hire（Note4）
Male
FemaleOf which full-time employees from contract
employees（Note5）
Number of Directors（Note6）
Of which female directors
Ratio of female directors
Number of senior management（Senior Manager or above）
Of which female senior management
Ratio of female senior management
Turnover ratio（Note7）

The end of April
2019

The end of April
2020

The end of April
2021

The end of
April 2022

KPI target for
FY2030

TFHD GroupFY2030 KPI

93
55
38
41
21
20
12
2
10
6

97
55
42
47
25
22
12
1
11

106
59
47
53
30
23
14
1
13

103
60
43
56
32
24
13
1
12

－
－
－
－
－
－
－
－
－

－
－
－
－
－
－
－
－
－

2

1

1

－

－

40
32
8
40.9%
3
0
3
10
3
7

38
29
9
43.3%
7
1
6
8
5
3

39
28
11
44.3%
8
2
6
6
5
1

34
27
7
42.0％
9
3
6
6
5
1

－
－
－
50.0%
－
－
－
－
－
－

－
－
－
over50%
－
－
－
－
－
－

2

1

0

1

－

－

4
1
25.0%

4
1
25.0%

4
0
16.6%（Note9）

4
2
50.0％

－
－
50.0%

－
－
－

27

29

31

32

－

－

4
14.8%
0.0%

3
10.3%
1.0%

5
16.1%
0.0%

5
15.6％
4.7％

－
40.0%
1.0%

－
over20％－(Note2)（Note8）（Note1）Full-time, contract and seconded employees（Note2） Number of Persons as of end of April 2019 is the total number from FY2017（Note3） Tokyu Land Corp. and Tokyu Community Corp.
（Note4）Full-time employee（Note5） Implemented from FY2018（Note6）Including part-time staff（Note7）Full-time（Note8） Shared Group-wide criteria for TFHD Group FY2030 KPI （Note9） Only this item shows the figures as of June 2021.

49

Society
Status of Work-Style Reform and Diversity Promotion
FY2017FY2018FY2019FY2020

FY2021KPI target for2030

TFHD GroupFY2030 KPIHealth check participation

97.7%

100%

96%

94.7%

100％

100.0%

100%

Stress check participation

94.3%

97.8%

100.0%

98.9%

100％

100.0%－

Annual paid leave per person

11.5days

10.8days

11.5days9.9days

11.1

－

－

Ratio of disabled employees

0.0%

0.0%

1.2%

1.0%

1.0％

2.3%

－

Number of employees aged 60 or above

1

1

1

3

2

－

－

Foreign employees

0

0

0

1

1

－

－

22.5hours

29.4hours

21.2hours

19.4hours

24.0hours

－

－

0

0

0

0

0

－

－

Absentee rate

0.5%

0.3%

0.5%

0.4%

0.3％

－

－

Ratio of employees on leave

0.0%

0.0%

0.0%

0.0%

1.0％

－

－

Childcare leave users

0

0

0

3

6

－

Childcare short working hour/childcare
off-peak commuting users（Note1）

Ratio of malechildcare leave
100％

1

2

1

0

5

－

－

Nursing-care leave users

0

0

0

0

0

－

－

Home Office utilization rate

―

―

100%

100%

100％

－

－

Item

Monthly average overtime
Number of workers’ injuries/death incident（Note2）（Note4）（Note3）（Note1） A system that allows flexible work hours corresponding to lifestyle (example: 8:00-16:30 work) （Note2）Utilization rate of work-from-home between March and April 2020
（Note3） Shared Group-wide criteria for TFHD Group FY2030 KPI （Note4） Only this item shows the figures as of June 2021.

50

Society
Initiatives to Local Communities
CRR and TRM believe that contribution to local communities lead to the improvement in value of the CRRʼs owned properties and ultimately by the unitholder value.
We make a variety of efforts in the owned properties to enhance communication with the local communities with an expectation that our business operation is to serve
an important role for the society.

Security of the local community
There is a police box on thepremises of COMFORIASHINJUKU EASTSIDE TOWER,
contributing to the security of thelocal community.

Contribution to the region
TRM periodically participate in“town cleaning” sponsored bygreen bird (specified non-profit
corporation).

Bicycle/Scooter Sharing services
Until August 1, 2022, we have introduced
bicycle sharing space at 14 properties toprovide convenient and healthytransportation vehicles to residents living
in and nearby, making the connection to
local station or neighborhood faster andcloser, and contribute to the smart city
planning of Tokyo.

Installation of donation-type vending machines
To improve the safety and sense of security of residents
and the local community, we have installed disaster
response vending machines at some of the properties
owned by CRR. These machines can provide drinks asrelief supplies to victims of strong earthquakes,
typhoons, and other natural disasters.

Corporate version Hometown Tax Payment
Through the regional revitalization support tax system,
TRM made a donation to a fundraising program in orderto support medical staff in Hokkaido pref. where CRR
owns a property. This donation is a part of efforts to“contribution to local communities”, one of the Materialitythat CRR shares with TRM.

Disaster provision warehouse and manhole toilets
At COMFORIA SHINJUKU EASTSIDE TOWER, we haveestablished a disaster provision warehouse designated by
the Shinjuku ward and manhole toilets for neighboring
residents and workers in preparation for a disaster. We
have also entered into an emergency mutual assistanceagreement with three neighboring town councils tostrengthen partnerships.
51

Society
Initiatives to Tenants
CRR believes that its owned properties should always meet tenant preferences to enhance the medium- to long-term value of our unitholders, and therefore tenantsatisfaction serves an essential role for that. To that end, we consistently communicate with them to understand their needs and reflect them for our asset management
operation.

Conduct Tenant satisfaction survey
Every year we carry out a questionnaire survey of the residents of the Comforia series, which are operated by CRR, on the Comforia brand as well as residents’ satisfaction
and requests regarding management and operation. Based on the opinions and requests of residents, we take actions with the aim of providing better services. An exampleof how we have improved tenant satisfaction is the increase in the number of delivery lockers in response to the opinion that there were not enough lockers due to therecent rise of e-commerce.
SurveyBuilding Cleaning(Common Areas)

Building Management& Service

2017

2018

2019

2020

2021

Satisfied

73％

68％

72%

73%

74％

Neutral

14％

18％

15%

13%

12％

Unsatisfied

13％

14％

13%

14%

14％

Satisfied

68％

67％

69%

68%

69％

Neutral

26％

22％

24%

24%

21％

Unsatisfied

6％

11％

7%

8％

10％

COMFORIA WELBOX

Exclusive Area Value UP (COMFORIA MINAMISUNAMACHI)COMFORIA WELBOX provides a wide range ofservices to the residents of the Comforia series,
which are operated by CRR. In addition tovarious discounts using the Group’s resources,
we offer preferential rates for moving to anotherproperty in the Comforia series and we carry out
resident satisfaction surveys using the
COMFORIA WELBOX platform in an effort toimprove resident satisfaction with the aim ofencouraging longer periods of residence.

The unused common room has been renovated to a 3bedroom units
targeted family tenants, with working space and multifunctional LED
ceiling light, which meet the family needs and create new income instantly.
BeforeAfter

52

Society
Supply of emergency kits and evacuation map
After the Great East Japan Earthquake, to enhance the safety and the senseof security of our residents, we provide emergency kits (emergency food andgoods) in the elevators of every property, we also post evacuation maps incommon space of all properties to inform residents of area for evacuation in
preparation for an earthquake or other disaster.

Cooperation with tenants
As part of our initiatives in collaboration with tenants, we created and distributed a
Sustainability Guide. This guide promotes reduction of households’ environmental
footprint, primarily through energy saving and the 3 Rs, and tenants are pursuing
various efforts aimed at the realization of a sustainable society.

Preventive measures against COVID-19(CRR)
Implemented measures of putting posters of infections disease measures toraise tenants’ attention, and setting alcohol-based hand sanitizers in common
spaces, etc.
 Infections disease measuresposters

Effort to advance health / wellness Alcohol-based handsanitizer
Comforia ITABASHI NAKAJUKU
provided running lessons for tenants
which were organized by Tokyu Sports
Oasis, Inc.

53

Society
Initiatives to Suppliers

TRM recognizes the importance of cooperation with its suppliers, as stated in the Sustainability Policy, that it provides initiatives and procurement with consideration
to the environment and society, through engagement to suppliers such as PM , BM , Appraisal companies and Engineering Report companies etc. As part of theinitiatives, TRM established the Green Procurement Standard and monitors ESG consideration in the operation of its important suppliers including PM and othercompanies.

Joint seminars

Label Free Drink
We work to foster a culture that ESG
initiatives are to be taken by ourentire supply chain, not limited to theofficer and employees of TRM. To
that end, ESG training sessions are
co-organized by TRM and PMs. In
FY2020, TRM organized also virtual
seminars themed ESG trend,
Materiality and application of theGreen Procurement Standard.

Since April 2022, TRM has introduced
label-free pet bottle drinks to reduceusage of plastic and simplify wastesorting. The label free drinks are provided
to visitors and employees, procured fromsuppliers who are committed to work forsustainable society and environment, forthe purpose of enhancing theenvironment protection consciousness.

Local staff awards

At COMFORIA SHINJUKU EASTSIDE TOWER,
we provide awards for concierge staff.
In addition to increasing the motivation of thesestaff members, we believe this helps to establish
an operating structure with a feeling of
togetherness between asset management andbuilding management personnel.

54

Society
Green Procurement Standard
As a member of TFHD Group, TRM shares the Groupʼs “Sustainable Procurement Policy” published on January 31, 2020 and works on challenges to environmental
crisis such as climate change. Our objective is to work on this goal, together with all the stakeholders including our suppliers. In line with the Groupʼs procurement
policy, TRM established the “Green Procurement Standard” to translate the policy into practical measures. This standard broadly states to suppliers that environmentfriendly procurement is to be carried out, and together with them, TRM works to promote more sophisticated efforts based on the Policy. The scope of application ofthis standard includes direct or indirect transactions related to products, services, raw materials, and design/construction procured by TRM and CRR.
TFHD Group Sustainable Procurement Policy Articles
1)Legal compliance1)-1 Total compliance with relevant laws and regulations2)Respect for human rights2)-1 Compliance with and respect for international humanrights and labor standards2)-2 No tolerance of discrimination2)-3 No tolerance of harassment2)-4 Respect for local residents2)-5 Respect for minority rights

3)Ensuring a work
environment based onsafety,health and well-being3)-1 Freedom of association, collective bargaining rights3)-2 No tolerance of forced labor3)-3 No tolerance of child labor3)-4 Fair wages3)-5 Elimination of excessive working hours3)-6 Workplace health and safety measures3)-7 Emergency preparedness3)-8 Prevention of occupational accidents and illness3)-9 Industrial Hygiene measures3)-10 Measures for physically demanding work3)-11 Proper sanitary facilities, meals and housing3)-12 Protection of foreign and migrant worker rights

4)Ensuring proper businessethics4)-1 Preventing corruption4)-2 Preventing contact with organized crime4)-3 Ensuring fair trade practices4)-4 Appropriate response to conflicts of interest4)-5 Responsible political involvement4)-6 Protection of intellectual property rights4)-7 Maintaining confidential information anddisclousure4)-8 Compliance hotline and whistleblower protection5)Environmental measures5)-1 Combatting climate change5)-2 Biodiversity protection5)-3 Protection of pollution5)-4 Effective use of resources5)-5 Proper water use
5)-6 Ensure appropriate use of forest resources6)Improving service and quality6)-1 Ensuring safety6)-2 Quality control and quality assurance systems6)-3 Proper information disclosure for products andservices

7)Proper information
management7)-1 Proper information management8)Business Continuity Planning8)-1 Business Continuity Planning9)Contributing to local
communities9)-1 Contributing to local communities

10)Extension of the Sustainable
Procurement Policy10)-1 Extension to business partners
10)-2 Cooperation for monitoring55

Society

Initiatives Complying with Green Procurement Standards
Environment-friendly/Energy-efficiency construction materials/facilities Lists
have been made and used as attachments in bid specifications for Large-scale
repair work.

COMFORIA SASAZUKA

Recyclable
Tile Carpet adopted toenhance resource efficiency

56

Society
Initiatives to Investors
CRR and TRM view appropriate information disclosure to and proactive dialogue with investors as essential tasks.
Based on the policy described above, TRM holds regular meetings with institutional investors in Japan and from abroad (Europe, North America, Asia, etc.).
In addition, it is engaged in proactive information disclosure by holding briefings for individual investors, participating in events and online seminars aimed at individual
investors, publishing presentation videos of financial result briefings, and more.
IR activities for domestic and foreign institutional investors◆

Sep.2021～Dec.2021

Sep.17
Presentation Video

23rd

◆

Presentation Video◆

One-on-one Meetings◆

Online conference

99 companies◆

One-on-one Meetings

84 companies

once

FP

Aug.2021

Mar.2022～Jul.2022

Mar.17

24th

FP

Sep.

Oct.

Nov.

Dec.

Jan.2022

Feb.

Mar.

◆

May.14

Apr.

May.

Jun.

Jul.

IR activities for individual investors◆

Oct.9
SMBC Nikko Securities
WEB J-REIT Fair 2021◆

Oct.30Online IR Seminar

Online IR Seminar◆Jun.29Nikkei J-REIT/Infrastructure
Fund WEB Seminar57

Initiatives at COMFORIA SHINJUKU EASTSIDE TOWER

With a site area of more than 1,000 square
meters, COMFORIA SHINJUKU EASTSIDETOWER has developed a greening plan inaccordance with the Ordinance for theConservation and Restoration of Nature inTokyo, based on which it offers a lush
space filled with natural features.

Energy-efficient glass is used in thewindows to reduce the amount of sunlightand heat that enters, in this way
alleviating the burden on the airconditioning systems.

A large windowed entrance allows the useof natural daylight.

An open space is used as a walkway forneighboring residents and commuters.

Artworks of our Shinjuku 6-chome Plan Art
Project are exhibited on the premises andinside the building.

AEDs (automated external defibrillators) areinstalled in the disaster control center and at
the pool on the 32nd floor.

Monthly pool events (SUP YOGA,
swimming clinic, water aerobics, etc.) are
held exclusively for residents.

Pamphlets in Foreign Languages

Resident Satisfaction Surveys

To further improve user satisfaction, user guides forresidents from overseas are provided at Comforia
Shinjuku Eastside Tower. The guides are prepared in
English, Chinese, and Korean.

A questionnaire survey of residents is carried out oncea year and the issues identified are then improved.
Improvements：
Room temperature adjustments in each facility
Cleaning of gym equipment
Enhancement of lounge menus, etc.

58Governance

Our View on Governance
We have established a comprehensive corporate
governance and compliance management structure andconduct ourselves in a highly ethical manner in order tomeet the expectations and earn the trust of society.

GovernanceRelevant SDG targets

12.8 By 2030, ensure that people everywhere have the relevant information and awareness for sustainable development and lifestyles inharmony with nature
16.7

Ensure responsive, inclusive, participatory and representative decision-making at all levels

CRR’s Corporate GovernancePursuant to the Act on Investment Trusts and Investment Corporations (“ITA”), CRR entrusts its asset management operations to TRM.
 CRR’s governance structure
CRRʼs organization comprises a unitholdersʼ meeting, a board of directors currently comprised of executive director and supervisory director, and an independent auditor.
It is stipulated that CRR shall have at least one executive director and at least two supervisory directors (however, the number of supervisory directors must be at least one
more than the number of executive directors). As of the end of July 2022, there were one executive director and two supervisory directors.

Unitholders’ Meeting

Board of Directors

Executive Director: Takehiro Izawa
Supervisory Director: Koji Yamamoto
Supervisory Director: Masamichi Ohshima

Independent Auditor
Ernst & Young ShinNihon LLC

 Unitholdrs’ meeting
Matters and issues on CRR, that are originally stipulated at ITA and other relevant laws & regulations, are to be resolved at unitholdersʼ meeting.

60

Governance Executive Director and Supervisory Directors
The term of office for directors and supervisory directors based on regulations are two years.
Position

Name

Number of Units Held

Executive Director

Takehiro Izawa－

Koji Yamamoto－

Masamichi Ohshima－

Supervisory Directors

 Eligibility requirements
Candidate for directors must not fall under any disqualification clause as defined in the ITA. Such candidates shall be examined and appointed at a unitholdersʼ meeting.

 Compensation
The maximum compensation amounts for the executive director and supervisory directors are stipulated in the articles of incorporation, and compensation is determinedby the board of directors.
Compensation received（¥ thousand / fiscal period）

Position

Name

Concurrent positions

Executive Director

Takehiro Izawa

Executive Director, Chief Division Officer of Comforia Management
Division, TLC REIT Management Inc.

Koji Yamamoto

Partner, WAKABA PARTNERS Law And Accounting Office

1,800

Kataoka & Kobayashi

1,800

－

Supervisory Directors
Masamichi Ohshima Board of Directors
At the meeting of the board of directors, the executive director reports on the performance of its duties and the supervisory directors supervise to ensure that CRR operates
the asset management in compliance with legal and regulatory requirements. The meeting frequency of the board should be at least once in three months as stipulated underinternal regulations of CRR. However, it is held every month with a 100% attendance of directors in FY2021.

61

Governance Independent auditors
The independent auditor shall audit the financial statements of CRR and report to the supervisory directors any improper activity of the executive director. The term of office of the
independent auditor comes to an end at the first unitholdersʼ meeting held after the first financial period closed after one year or more from the appointment date. The auditor shallbe reappointed except as otherwise resolved in a unitholdersʼ meeting.
Excerpt from the semi-annual report for the fiscal period ended July 2022
Position

Name

Independent auditor

Ernst & Young ShinNihon LLC

Compensation（¥ thousand / period）
15,138(Note)（Note）The amount includes the fees pertaining to the production of an “Auditor’s Comfort Letter to Lead Underwriting Firm” related to the issuance of CRR bonds conducted in July 2022.

62Governance
TRM’s Corporate Governance
TRM works to enhance corporate governance to exercise a fiduciary duty and a duty of loyalty to CRR as stipulated in the asset management agreement.
 TRM management organization
Under the management organization shown below, TRM exercises its asset management operation, and the Comforia Management Division undertakes the management ofassets of CRR. TRM has established the Investment Committee and the Compliance Committee to deliberate matters related to asset management and compliance, and theAcquisition Priority Review Meeting to determine the order of priority for consideration. In April 2021, TRM established the rules on the Sustainability Promotion System tostrengthen the system and expand the functionality of measures. Following this, the Sustainability Promotion Council obtained a more accurate position in the organization. The
Sustainability Department succeeds the ESG-related missions from the Environmental Engineering Department, and we will further promote our sustainability program.
Shareholders’ Meeting
Corporate Auditor
Board of Directors
Investment Committee

Compliance Committee
President & CEO

Sustainability Promotion
CouncilAcquisition Priority
Review Meeting

Internal Audit Dept.

Compliance Dept.

Corporate
Management
Div.

Corporate
Planning
Dept.

Human
Resources
Dept.

Finance &Accounting
Dept.

Sustainability
Dept.

Activia
Management Div.

DigitalTransformation

Promotion
Dept.

Asset
Investment
Dept.

Environmental
Engineering
Dept.

Strategy
Dept.

Asset
Management
Dept.

Comforia
Management Div.

Strategy
Dept.

Asset
Management
Dept.

Broadia
Management
Div.

Strategy
Dept.

Asset
Management
Dept.

63

Governance Compliance

TRM has established a Compliance Department and Compliance Committee, which ensure that compliance checks are implemented. The Compliance
Committee is a body that discusses and makes resolutions regarding conflicts of interest, transactions with related parties, internal compliance, andcompliance readiness. Compliance management is implemented in adherence to the TFHD Group Code of Conduct.

Compliance Policy

Key points of “TFHD Group Code of Conduct”
1.Ensure compliance with laws and regulations applicable to our business activities
2. As TFHD Group employee, treat our customers sincerely to maintain their trust
3. Generate a corporate culture that enables frank communication on difficult issues involving work
4. Enhance solidarity of TFHD Group and promote mutual understanding with stakeholders
5. Enforce proper management of information
6. All employees will understand and focus on ethical conducts and be a reasonable professional
7. Make efforts to create safe workplace and be considerate of the environmental conservation（Members）
General Manager of Compliance Department (Chair), representative directors, directors (if consecutively serving as General Manager of the Investment
Management Division, cannot attend Council meetings concerning REITs that the director is not in charge of), and external expert (attorney) on complianceappointed by the board of directors.
(Agenda)The Council shall resolve the following matters.
With respect to 1 to 5 , agenda shall be restricted to transactions with related parties and matters deemed necessary by the General Manager ofCompliance Department.

Compliance Committee

1. Establishment and amendment of basic investment policy concerning asset management by each REIT
2. Determination and change in acquisition or disposal of assets by each REIT and the terms and conditions thereof
3. Establishment and amendment of asset management plan by each REIT
4. Establishment and amendment of basic policy concerning asset management by each REIT
5. Establishment and amendment of basic policy concerning funding, capital policy and dividend policy for each REIT
6. Matters related to transactions with related parties (provided, however, excluding transactions defined as not requiring prior approval by theCompliance Council)
7. Preparation and amendment of the Compliance Manual and Compliance Program
8. Deliberation and resolution on improvement measures concerning inappropriate acts in terms of regulatory compliance and preventative
measures, etc.
9. Matters for which the General Manager of Compliance Department deems deliberation by the Compliance Council is necessary（Date and place）
As a general rule , the committee meets at the head office at least once every three months.

64

Governance Measure taken to enhance compliance awareness
Divisional Compliance Staff

Each year, divisional compliance staff are appointed from each division to perform periodic monitoring on compliance matters. The officers
report compliance status in his/her division and share related information.

Compliance training

In order to ensure compliance and increase awareness, we provide over twice compliance trainings each year to all officers and employees
focusing on the enforcement of the compliance basic policy and standards, and learning applicable laws and regulations, etc., and provide
orientation and follow-up (for employees new to the financial instruments business, after six months have passed since hiring).

 Internal Auditing and Monitoring System
In its internal auditing regulations, TRM has formulated an internal auditing plan, which stipulates that internal auditing shall be conducted for all departments each fiscal year, withthe exception of the Internal Audit Department. As an asset management company, with a view to investor protection and fair market formation, it audits whether tasks related toreadiness in the areas of legal compliance, internal control, risk management, crisis management, etc. are being carried out appropriately and efficiently. Furthermore, with thesupport of external professionals, it audits a wide range of items for all departments, such as the appropriateness of information management, compliance with internal rules, andadherence to the Act on Prevention of Transfer of Criminal Proceeds and reports the audit results to TRM’s representative directors and board of directors. Matters detected by anaudit are communicated to the audited department via a ”Directive for Improvement,” and the head of the audited department that was notified implements improvement actions
and reports on the status of the improvements to the representative directors and the head of the Internal Audit Department without delay. The department in charge of auditing
also periodically verifies the status of improvements.
The 10 Principles of the UN Global Compact

 Prevention of Corruption
Corruption creates significant obstacles against sustainable development and corrodes
the social structure. TRM recognizes that commitment to prevention of corruption is an
important issue for the society and has established rules on identity confirmation fortransaction with customers, etc. in accordance with the Act on Prevention of Transfer of
Criminal Proceeds.
TFHD is a signatory to the United Nations Global Compact (UNGC), and as a Group
member, TRM supports the ten principles of UNGC. (Principle 10. Businesses should
work against corruption in all its forms, including extortion and bribery.)HumanrightsPrinciple 1: Businesses should support and respect the protectionof internationally proclaimed human rights; andPrinciple 2: make sure that they are not complicit in human rights
abusesLabor

Principle 3: Businesses should uphold the freedom of associationand the effective recognition of the right to collective
bargaining
Principle 4: the elimination of all forms of forced and compulsory
labor:
Principle 5: the effective abolition of child labor; andPrinciple 6: the elimination of discrimination in respect of
employment and occupation

Environment

Principle 7: Businesses should support a precautionary approachto environmental challenges;
Principle 8: undertake initiatives to promote greater
environmental responsibility; andPrinciple 9: encourage the development and diffusion ofenvironmentally friendly technologies

Anticorruption

Principle 10: Businesses should work against all forms ofcorruption, including extortion and bribery

Supporting International Initiatives
The TFHD Group supports and respects the OECD Guidelines for Multinational
Enterprises, international labor standards, and the UN’s Guiding Principles on
Business and Human Rights. Moreover, it declared its support for the UN Global
Compact in December 2016. It is pursuing responsible management based on the 10
principles of the UN Global Compact, which is composed of “human rights,” “labor,”“environment,” and “anti-corruption,” and contributing to the realization of a sustainable
society.

65

Governance Official Policy Against Antisocial Forces
In order to safeguard the propriety of its business activities and ensure that we are able to meet our social responsibilities and fulfill our public mission, TRM abjures dealings ofany kind with antisocial forces.
Working with legal and law enforcement bodies and other third parties, TRM is in a position to respond firmly to all improper demands. TRM’s Compliance Manual and Rules for
Responding to Antisocial Forces has established specific safeguards and procedures for responding to the actions of antisocial forces. TRM also promotes a thorough awarenessof these issues among management, employees, and other pertinent parties and provides the training needed to ensure a specific and appropriate response.

TFHD Group’s Whistle-blowing System

 Establishment of whistle-blowing system
TRM established the Compliance Helpline Counter as a contact point to report andconsult on compliance matters including when harassment and bullying is
experienced or observed, enabling all officers and employees to directly report to theCompliance Officer of TRM, General Manager of Legal Affairs Department of TLC,
General Manager of Group Legal Affairs Department of TFHD, or external attorneys.
Moreover, we pledge to maintain the confidentiality of personal information or
investigation-related information about the individual who reported or consulted on thematter and the subject of the report or consultation, which shall not be disclosed
internally or externally without good reason.

Item

FY2017FY2018FY2019FY2020

FY2021

TFHD GroupFY2030 KPI

Adherence with Compliance Code of Conduct

100%

100%

100%

100%

100%

100%

Awareness of Compliance Helpline Counter

89%

90%

87%

90%

88%

－

（Note）Shared Group-wide criteria for TFHD Group FY2030 KPI

66

Governance Risk Management
TRM established a basic policy on the strategic targets, as well as risk management rules to implement appropriate management of risks.
(Basic Policy on Risk Management)

Basic Policy on Risk
Management

1. In accordance with our management principles, we aim to secure long-term stable revenue and maximize unitholder value by establishing amanagement system in accordance with these Rules and implementing appropriate risk management against various risks involved withengaging in investment management business.
2. Officers and employees, etc., shall recognize the importance of risk management, each be aware that they are the agent of risk management,
understand these Rules and internal rules, etc., and strictly comply with the same .
3. Risk management shall be executed with necessary and appropriate rules, detailed rules and standards, etc., being established; organizationaland resource measures implemented; and responsibilities clarified.
4. Necessary and appropriate management and supervision shall be implemented for business outsourcing partners as well as to officers andemployees, etc.
5. Risk management training, etc., shall be conducted to promote thorough awareness by officers and employees, etc., and to maintain/improve
effectiveness of the Basic Policy.
6. Basic Policy stated in this Article shall be reviewed periodically or as necessary such as when changes occur to strategic targets.

Risk management
framework

TRM conducts sophistication of its risk management framework with a certain support from external experts. Risk management function falls under the
responsibility of the Compliance Department supervised by the Compliance Officer. The Compliance Department is a stand-alone department, independent
from business operating divisions. It performs a series of risk assessment including operational risk, etc.

Risk management
training

TRM provides periodical risk management educational session with all officers and employees by external lecturers and works to improve risk
management ability of each department's members.

Information security

In order to enhance security of information assets and appropriate use of them, TRM has set forth basic rules on information security management which
stipulates principal matters related to information protection with clarifying the responsibility for information management. TRM has also established therules on IT management to stipulate appropriate management of information asset by each officer and employee according to the level of their roles andresponsibilities.

Business continuity
planning

To strengthen its resilience, TRM sets a business continuity plan, related rules and manuals, and makes updates when necessary, in preparation for
unexpected crisis such as disaster and social disruption. In accordance with these rules, we work to prevent and mitigate impact from crisis including
recent natural disasters and COVID-19. We also pay close attention to the materials and equipment used in the properties of CRR and make every effort toprevent incident by staying well informed of defect products and carrying out research.

67

GovernanceInitiatives for Governance Emphasizing Unitholders’ Value
While leveraging the TFHD Group’s value chain, CRR and TRM have developed a comprehensive governance structure aimed at maximizing CRR unitholders’value by ensuring objectivity in the asset management-related decision-making flow, aligning our interests with unitholders and sponsor, and implementing amanagement fee structure that includes management fees linked to the dividend per unit.

Securing objectivity in decision-making process
With a view to protecting the interests of unitholders, TRM has established a structure that ensures objectivity in the decision-making process for acquiring assets
under management by including third-party real estate appraisers as members of the Investment Committee.
Proposal by responsible department

Approval by Compliance Officer
In case of related-party transactions and other necessary cases

Compliance Committee deliberation and resolution (Note1)

Investment Committee deliberation and resolution(Note2)

Approval by each Chief Division Officer
In case of related-party transactions and other necessary cases

Prior approval by CRR’s board of directors(Note1)

Report to CRR

Report to the Board of Directors（Note1）Deliberation and resolution by the Compliance Committee as well as prior approval by CRR’s board of directors will be required for acquiring assets, etc.
In case of related-party transactions and other necessary cases.

（Note2）If the candidate acquisition asset is a healthcare facility, advisory from external experts related to healthcare facilities shall be sought. Furthermore, discussions shall be held upon receiving a reporton the content of reports, etc. created by external experts related to healthcare facilities and, if necessary, the Investment Committee shall be attended by the concerned external experts as observers
and their opinions shall be heard.

68

GovernanceAligning Interests Between Unitholders and the Sponsor
In the Sponsor Support Agreement, TLC has made it clear that if and when CRR decides to issue additional units, a subscription of a part of such issuance shall besincerely considered.
In the public offering held in Feb.2022, the sponsor acquired 2,410 units, which is 10% of the number of issuing units. Even in terms of capital relationship, CRR aims to
make a strong relationship with the sponsor and to achieve mutual interests improvement by aligning the interests of unitholders to that of the sponsor.

Sponsor’s investment ratio

9.0%（as of July 31, 2022）
Change in Asset Management Fee System
Under the asset management fee structure that has been applied since August 1 , 2020, Incentives have been introduced for further improvement of and growth ofunitholder value and enhanced linkage with the interests of unitholders.
Before change

Current

Total assets at the end of previous fiscal
period×0.3％（annual rate）

Total assets at the end of previous fiscal
period×0.2％（annual rate）

Management feeⅡ

Ordinary CF × 3.0％

Ordinary CF×5.4％

Management feeⅢ

Property acquisition / disposition price×1.0％

Property acquisition / disposition price×1.0％

Management fee Ⅰ（fee linked to total assets）（fee linked to profit）(acquisition and disposition fee)Management feeⅤ
（incentive）

Newly established（0.5％ in the case of transactions with related parties）―(0.5％ in the case of transactions with related parties(excluding warehousing))

Ordinary CF×growth rate of ordinary CF
per unit ×10％

Enhancing the linkage between
the interests of unitholders andasset management fees

Strengthening incentives for
growth of AUM and distributions

However, no fee will occur when the value is negative

69

GRI Content Index

Disclosure
GRI 100: Universal Standards
102: General Disclosures 2016
1. Organizational Profile
102-1
Name of the organizationa Name of the organization
102-2

102-3

102-4

102-5

Activities, brands, products, andservices
A description of the organization’saactivities.
Primary brands, products, and services,
including an explanation of any productsbor services that are banned in certain
markets.

Location of headquarters
Location of the organization’saheadquarters.
Location of operations
Number of countries where theorganization operates, and the names ofa countries where it has significant
operations and/or that are relevant to the
topics covered in the report.
Ownership and legal forma Nature of ownership and legal form.

102-6

Markets serveda Markets served, including:i. geographic locations where products
and services are offered;ii. sectors served;
iii. types of customers and beneficiaries.

REIT
Location or reason for omission

Asset Manager
Location or reason for omission

https://www.comforiareit.co.jp/en/about/profile.html

Profilehttps://www.tokyu-trm.co.jp/en/profile/Profilehttps://www.comforiareit.co.jp/en/features/index.html

Basic Policies

https://www.tokyu-trm.co.jp/en/profile/Profilehttps://www.comforiareit.co.jp/en/features/index.html

Basic Policies

https://www.tokyu-trm.co.jp/en/index.html

Home

Portfolio List

https://www.tokyu-trm.co.jp/en/profile/Profilehttps://www.comforiareit.co.jp/en/portfolio/index.html
https://www.comforia-reit.co.jp/en/ir/library.html

Semi-Annual Reporthttps://www.comforiareit.co.jp/en/about/profile.html

Profilehttps://www.tokyu-trm.co.jp/en/profile/Profilehttps://www.comforiareit.co.jp/en/about/profile.html

Profilehttps://www.tokyu-trm.co.jp/en/profile/Profilehttps://www.comforiareit.co.jp/en/about/structure.html

Structurehttps://www.tokyu-trm.co.jp/en/profile/ProfileProfilehttps://www.tokyu-trm.co.jp/en/profile/ProfileProfilehttps://www.tokyu-trm.co.jp/en/profile/ProfileStructurehttps://www.tokyu-trm.co.jp/en/profile/ProfileCapital &Unitholders

https://www.tokyu-trm.co.jp/client/

Customer-first
Business Operation
Policy (in Japanese)

https://www.comforiareit.co.jp/en/about/profile.html
https://www.comforiareit.co.jp/en/about/profile.html
https://www.comforiareit.co.jp/en/about/structure.html
https://www.comforiareit.co.jp/en/finance/investment.html

70GRI Content Index

102-7

Disclosure
Scale of the organizationa Scale of the organization, including:i. total number of employees;
ii. total number of operations;iii. net sales (for private sector
organizations) or net revenues (for public
sector organizations);
iv. total capitalization (for private sector
organizations) broken down in terms ofdebt and equity;
v. quantity of products or services
provided.

102-8

Information on employees and otherworkers
Total number of employees bya employment contract (permanent andtemporary), by gender.
Total number of employees byb employment contract (permanent andtemporary), by region.
Total number of employees byc employment type (full-time and part-time),
by gender.
Whether a significant portion of theorganization’s activities are performed byworkers who are not employees. Ifdapplicable, a description of the nature andscale of work performed by workers who
are not employees.
Any significant variations in the numbers
reported in Disclosures 102-8-a, 102-8-b,e
and 102-8-c (such as seasonal variationsin the tourism or agricultural industries).

REIT
Location or reason for omission

Asset Manager
Location or reason for omission

https://www.comforiaStructure
reit.co.jp/en/about/structure.html
Due to legal restrictions, there are no employees
in the investment corporation, and management
is entrusted to the asset management company,
TLC REIT Management Inc.
1(Head Office only)

https://www.tokyu-trm.co.jp/en/profile/Profilehttps://www.tokyutrm.co.jp/en/sustainability/esg.html#c3

Key Employee Data

1(Head Office only)

https://www.comforia-reit.co.jp/en/ir/highlight.html Financial Highlights
https://www.comforiareit.co.jp/en/finance/index.html
https://www.comforiareit.co.jp/en/portfolio/index.html
Since the investment corporation does not have
employees due to legal restrictions,
implementations by the asset managementcompany's employees are applicable to this
topic.

Interest-Bearing
Debt

https://www.tokyu-trm.co.jp/en/profile/ProfilePortfolio List

https://www.tokyu-trm.co.jp/en/attention/

About Financial
Transactions

https://www.tokyutrm.co.jp/en/sustainability/esg.html#c3

Key Employee Data

The asset management company solely
operates at the Head Office, there is no regional
difference by region.
https://www.tokyutrm.co.jp/en/sustainability/esg.html#c3

Key Employee Data

Not applicable (major part of activities are
performed by employees)

No significant variations in the numbers reported.

71

GRI Content Index

102-9

102-10

REIT
Disclosure
Location or reason for omission
Supply chain
A description of the organization’s supply
Value chain of thechain, including its main elements as they https://www.comforia-reit.co.jp/en/features/basica
TOKYU FUDOSAN
policy_tokyu-fudosan-hd.html
relate to the organization’s activities,
HOLDINGS Group
primary brands, products, and services.
https://www.comforiaStructure
reit.co.jp/en/about/structure.html
Significant changes to theorganization and its supply chain
Significant changes to the organization’s
a size, structure, ownership, or supply
chain, including:
Notice Concerning
Change ofPresident & CEO
i. Changes in the location of, or changes https://www.comforia-reit.co.jp/file/en-newsand Appointment ofin, operations, including facility openings, b4100311cc3374acb5d18e397325e1465f59dc18. Chairman andclosings, and expansions;pdf
Directorsof the AssetManagement
Company
Notice Concerning
https://www.comforia-reit.co.jp/file/en-newsthe Resignation of
353adc225c46e298cd1441057a37ce29a52faeb7. Director at the
pdf
Asset Management
Company
Notice ofAmendments ofhttps://www.comforia-reit.co.jp/file/en-newsArticles of
49a1a7fe2557dd25f2321c12428e951e4ac6289c.
Incorporation andpdf
Appointment of
Directors
Notice Concerning
Changes in
Organizational
https://www.comforia-reit.co.jp/file/en-newsStructure and20b095279e98bdb68798cd070eaf05e5c09d1775.
Directors
pdfof the AssetManagement
Company
ii. Changes in the share capital structure
and other capital formation, maintenance,
No significant changes
and alteration operations (for private
sector organizations);iii. Changes in the location of suppliers,
the structure of the supply chain, orNo significant changes
relationships with suppliers, including
selection and termination.

Asset Manager
Location or reason for omission

https://www.tokyutrm.co.jp/en/sustainability/materiality.html

SDGs strongly
related to materiality

https://www.tokyutrm.co.jp/en/common/pdf/info_2106_en.pdf

Notice Concerning
Change ofPresident & CEO
and Appointment ofChairmanNo significant changes

No significant changes

72

GRI Content Index

102-11

102-12102-13

2. Strategy
102-14102-15Disclosure
Precautionary Principle or approach
Whether and how the organizationa applies the Precautionary Principle orapproach.

REIT
Location or reason for omission
https://www.comforiareit.co.jp/en/sustainability/index.html

External initiatives
A list of externally-developed economic,
environmental and social charters,
https://www.comforiaa principles, or other initiatives to which thereit.co.jp/en/sustainability/initiative.html
organization subscribes, or which itendorses.

Membership of associations
A list of the main memberships ofindustry or other associations, andnational or international advocacy
organizations.

https://www.comforiareit.co.jp/en/sustainability/initiative.html

Statement from senior decision-makerA statement from the most seniordecision-maker of the organization (suchas CEO, chair, or equivalent seniorhttps://www.comforiaa
reit.co.jp/en/about/index.html
position) about the relevance ofsustainability to the organization and its
strategy for addressing sustainability.
Key impacts, risks, and opportunities
A description of key impacts, risks, and https://www.comforiaa
opportunities.
reit.co.jp/en/sustainability/materiality.html
https://dev.comforiareit.co.jp/en/sustainability/climate.html

Asset Manager
Location or reason for omission

Sustainability Policy

International
Initiatives, etc.

International
Initiatives, etc.

https://www.tokyutrm.co.jp/en/sustainability/index.html

Sustainability
Policies

https://www.tokyutrm.co.jp/en/sustainability/esg.html#c4

Risk Management

https://www.tokyutrm.co.jp/en/sustainability/esg.html#c5

International
Initiatives

https://www.tokyutrm.co.jp/en/sustainability/gri.html

PAI Statement
P.7 5. References
to international
standards

The Investment Trusts Association, Japan
The Association for Real Estate Securitization
https://www.tokyutrm.co.jp/en/sustainability/esg.html#c5

International
Initiatives

Greetings

https://www.tokyu-trm.co.jp/en/message/

Message

Materiality

https://www.tokyutrm.co.jp/en/sustainability/materiality.html

Materiality

Addressing Climate
Change73

GRI Content Index
REIT
Disclosure
Location or reason for omission
3. Ethics and Integrity
Values, principles, standards, and102-16
norms of behavior
A description of the organization’s values,
https://www.comforiaa principles, standards, and norms ofreit.co.jp/en/features/index.html
behavior.

102-17

4. Governance102-18Asset Manager
Location or reason for omission

Basic Policies

Philosophy

https://tokyu-fudosan-hdcsr.disclosure.site/en/themes/47

Tokyu Fudosan
Holdings Group
Code of Conduct（Tokyu Fudosan
Holdings）※As a member of the Tokyu Land HoldingsGroup, we share the above policy.

Since the investment corporation does not have
employees due to legal restrictions,
Mechanisms for advice and concerns
implementations by the asset management
about ethics
company's employees are applicable to this
topic.

Governance structure
Governance structure of the organization,
https://www.comforiaa including committees of the highest
reit.co.jp/en/about/profile.html
governance body.
https://www.comforiareit.co.jp/en/about/structure.html
Committees responsible for decisionhttps://www.comforiab making on economic, environmental, andreit.co.jp/en/sustainability/index.html
social topics.

https://www.tokyu-trm.co.jp/en/philosophy/

https://www.tokyutrm.co.jp/en/sustainability/esg.html#c4

Establishment ofwhistle-blowing
systemhttps://www.tokyu-fudosanhd.co.jp/english/about/compliance/

Establishment ofComplianceHelpline

https://www.tokyutrm.co.jp/en/sustainability/gri.html

PAI Statement
P.5 Table 3(6.
Insufficientwhistleblower
protection)

https://www.tokyu-trm.co.jp/en/profile/ProfileStructurehttps://www.tokyu-trm.co.jp/en/organization/

Organization

Promotion System

https://www.tokyu-trm.co.jp/en/sustainability/

Promotion System

https://www.tokyutrm.co.jp/en/sustainability/gri.html

PAI Statement
P.6 3. Description ofpolicies to identify
and prioritize
principal adverse
sustainability
impacts

Officers

74

GRI Content Index

Disclosure102-19102-20Delegating authority

Executive-level responsibility foreconomic, environmental, and social
topicsWhether the organization has appointed
an executive-level position or positionsawith responsibility for economic,
environmental, and social topics.

b102-21

Whether post holders report directly tothe highest governance body.

REIT
Location or reason for omission
https://www.comforiareit.co.jp/en/about/governance.html
https://www.comforiareit.co.jp/en/about/structure.html
Due to the organizational characteristics, theresponsible officer is appointed in the asset
management company.
https://www.comforiareit.co.jp/en/sustainability/index.html

https://www.comforiareit.co.jp/en/sustainability/index.html

Consulting stakeholders on
economic, environmental, and social
topicsProcesses for consultation between
stakeholders and the highest governance https://www.comforiaa
body on economic, environmental, andreit.co.jp/en/sustainability/materiality.html
social topics.

2.Operational
system of theInvestment
Corporation

Asset Manager
Location or reason for omission
https://www.tokyu-trm.co.jp/en/sustainability/

Promotion System

https://www.tokyu-trm.co.jp/en/sustainability/

Promotion System

https://www.tokyutrm.co.jp/en/sustainability/gri.html

PAI Statement
P.6 3. Description ofpolicies to identify
and prioritize
principal adverse
sustainability
impacts

https://www.tokyu-trm.co.jp/en/sustainability/

Promotion System

https://www.tokyutrm.co.jp/en/sustainability/gri.html

PAI Statement
P.6 3. Description ofpolicies to identify
and prioritize
principal adverse
sustainability
impacts

https://www.tokyutrm.co.jp/en/sustainability/esg.html#c2

Commitment toEnvironment

https://www.tokyutrm.co.jp/en/sustainability/esg.html#c3

Commitment toSociety

Structure

Promotion System

Promotion System

SDGs with close
relevance to theMateriality

75

GRI Content Index

102-22102-23102-24102-25Disclosure
Composition of the highest
governance body and its committees

REIT
Location or reason for omission
https://www.comforiareit.co.jp/en/about/structure.html

Asset Manager
Location or reason for omission
Structurehttps://www.comforiaArticles ofreit.co.jp/file/ir_library_other_fileChair of the highest governance body
Incorporation (in81414b4dc9a22288429b883023a83ccf01293c74.
Japanese)
pdf
Nominating and selecting the highest
governance bodyhttps://www.comforiaNomination and selection processes for
Articles ofreit.co.jp/file/ir_library_other_fileIncorporation (inthe highest governance body and its
81414b4dc9a22288429b883023a83ccf01293c74.
Japanese)
committees.
pdf
https://www.comforiaCriteria used for nominating and selecting
Articles ofreit.co.jp/file/ir_library_other_fileIncorporation (inhighest governance body members,
81414b4dc9a22288429b883023a83ccf01293c74.
Japanese)
including whether and how:pdf
i. stakeholders (including shareholders)are involved;
ii. diversity is considered;iii. independence is considered;iv. expertise and experience relating toeconomic, environmental, and social
topics are considered.
Conflicts of interest
Processes for the highest governancehttps://www.comforiaGovernancea body to ensure conflicts of interest are
reit.co.jp/en/about/governance.html
Systemavoided and managed.
Report on
https://www.comforiaWhether conflicts of interest areManagement
reit.co.jp/file/ir_library_other_fileb disclosed to stakeholders, including, as a
Structure of theeede387438ddb7369330c6e05ad1b45c35d2231d
minimum:
REIT Issuer (in.pdfJapanese)i. Cross-board membership;
ii. Cross-shareholding with suppliers andother stakeholders;iii. Existence of controlling shareholder;iv. Related party disclosures.

https://www.tokyu-trm.co.jp/en/organization/

Organization

https://www.tokyu-trm.co.jp/en/profile/

Executive Board

https://www.tokyu-trm.co.jp/en/profile/

Executive Board

https://www.tokyutrm.co.jp/en/sustainability/esg.html#c4

Compliancehttps://www.tokyu-trm.co.jp/en/profile/Profile76

GRI Content Index

102-26102-27REIT
Disclosure
Location or reason for omission
Role of highest governance body insetting purpose, values, and strategy
Highest governance body’s and senior
executives’ roles in the development,
approval, and updating of thehttps://www.comforiaa organization’s purpose, value or mission
reit.co.jp/en/sustainability/index.html
statements, strategies, policies, andgoals related to economic, environmental,
and social topics.

Collective knowledge of highest
governance body
Measures taken to develop and enhance
the highest governance body’s collectiveaknowledge of economic, environmental,
and social topics.

Asset Manager
Location or reason for omission

Promotion System

https://www.tokyu-trm.co.jp/en/sustainability/

Promotion System

https://www.tokyutrm.co.jp/en/sustainability/gri.html

PAI Statement
P.6 3. Description ofpolicies to identify
and prioritize
principal adverse
sustainability
impacts

https://www.tokyutrm.co.jp/en/sustainability/esg.html

Promotion System

https://www.tokyutrm.co.jp/en/sustainability/gri.html

PAI Statement
P.6 3. Description ofpolicies to identify
and prioritize
principal adverse
sustainability
impacts

77

GRI Content Index

102-28102-29Disclosure
Evaluating the highest governancebody’s performance
Processes for evaluating the highest
governance body’s performance witharespect to governance of economic,
environmental, and social topics.

REIT
Location or reason for omission

Asset Manager
Location or reason for omission

https://www.tokyu-trm.co.jp/en/sustainability/

Promotion System

https://www.tokyutrm.co.jp/en/sustainability/gri.html

PAI Statement
P.6 3. Description ofpolicies to identify
and prioritize
principal adverse
sustainability
impacts

https://www.tokyutrm.co.jp/en/sustainability/materiality.html

Materiality

https://www.tokyutrm.co.jp/en/sustainability/gri.html

PAI Statement
P.6 3. Description ofpolicies to identify
and prioritize
principal adverse
sustainability
impacts
P.6 4. Due diligenceand screening

https://www.tokyutrm.co.jp/en/sustainability/materiality.html

Materiality

Identifying and managing economic,
environmental, and social impacts
Highest governance body’s role inidentifying and managing economic,
environmental, and social topics and their https://www.comforiaa
reit.co.jp/en/sustainability/materiality.html
impacts, risks, and opportunities –including its role in the implementation ofdue diligence processes.

Materiality

https://www.comforiareit.co.jp/en/sustainability/index.html

Promotion System

https://dev.comforiareit.co.jp/en/sustainability/climate.html

Addressing Climate
ChangeWhether stakeholder consultation is used
to support the highest governance body’s
https://www.comforiaidentification and management ofbreit.co.jp/en/sustainability/materiality.html
economic, environmental, and social
topics and their impacts, risks, andopportunities.

Materiality

78

GRI Content Index

Disclosure102-30Effectiveness of risk management
processes

102-31

Review of economic, environmental,
and social topics

REIT
Location or reason for omission
https://dev.comforiareit.co.jp/en/sustainability/climate.html
https://www.comforiareit.co.jp/en/about/governance.html
https://dev.comforiareit.co.jp/en/sustainability/climate.html
https://www.comforiareit.co.jp/en/sustainability/index.html

Asset Manager
Location or reason for omission

Addressing Climate
Changehttps://www.tokyuGovernance
Systemtrm.co.jp/en/sustainability/esg.html#c4
Addressing Climate
ChangePromotion System

Frequency of the highest governancebody’s review of economic,aenvironmental, and social topics and theirimpacts, risks, and opportunities.

102-32Highest governance body’s role insustainability reporting

https://www.tokyutrm.co.jp/en/sustainability/index.html

https://www.tokyutrm.co.jp/en/sustainability/gri.html

https://www.comforiareit.co.jp/en/sustainability/index.html

Promotion System

https://www.tokyutrm.co.jp/en/sustainability/index.html

https://www.tokyutrm.co.jp/en/sustainability/gri.html

102-34Nature and total number of criticalconcerns

No critical concerns reported during the reporting
period.

No critical concerns reported during the reporting
period.

Efforts on
Governance

Promotion System
PAI Statement
P.6 3. Description ofpolicies to identify
and prioritize
principal adverse
sustainability
impacts
Promotion System
PAI Statement
P.6 3. Description ofpolicies to identify
and prioritize
principal adverse
sustainability
impacts

79

GRI Content Index

102-35Disclosure
Remuneration policies
Remuneration policies for the highest
a governance body and senior executives
for the following types of remuneration:i. Fixed pay and variable pay, including
performance-based pay, equity-based
pay, bonuses, and deferred or vested
shares;ii. Sign-on bonuses or recruitment
incentive payments;
iii. Termination payments;
iv. Clawbacks;
v. Retirement benefits, including thedifference between benefit schemes andcontribution rates for the highest
governance body, senior executives, andall other employees.
How performance criteria in the
remuneration policies relate to the highest
governance body’s and senior executives’
objectives for economic, environmental,
and social topics.

102-36

REIT
Location or reason for omission

Asset Manager
Location or reason for omission

https://www.comforiaArticles ofreit.co.jp/file/ir_library_other_fileIncorporation (in81414b4dc9a22288429b883023a83ccf01293c74.
Japanese)
pdf

https://www.comforiaArticles ofreit.co.jp/file/ir_library_other_fileProcess for determining remuneration
Incorporation (in81414b4dc9a22288429b883023a83ccf01293c74.
Japanese)
pdf

https://www.tokyutrm.co.jp/en/sustainability/gri.html

Website Summary
for CRR
P.3
REMUNERATIONANDSUSTAINABILITYRISKS (SFDR
ARTICLE 5DISCLOSURE)

80

GRI Content Index

Disclosure
5. Stakeholder Engagement102-40
List of stakeholder groups
A list of stakeholder groups engaged byathe organization.
102-41
Collective bargaining agreementsa102-43102-44

Percentage of total employees coveredby collective bargaining agreements.

REIT
Location or reason for omission

https://www.comforiareit.co.jp/en/sustainability/examples.html

Asset Manager
Location or reason for omission

Examples of
initiatives

Since the investment corporation does not have
employees due to legal restrictions,
implementations by the asset managementcompany's employees are applicable to this
topic.

Approach to stakeholder engagement
The organization’s approach to
stakeholder engagement, including
frequency of engagement by type and byhttps://www.comforiaa stakeholder group, and an indication ofreit.co.jp/en/sustainability/examples.html
whether any of the engagement wasundertaken specifically as part of thereport preparation process.
Key topics and concerns raised
No key topics or concerns raised

https://www.tokyutrm.co.jp/en/sustainability/esg.html

Our commitment

100%

Examples of
initiatives

https://www.tokyutrm.co.jp/en/sustainability/esg.html#c3

Commitment toSociety

No key topics or concerns raised

81

GRI Content Index
REIT
Location or reason for omission

Disclosure
6. Reporting Practice102-45102-46102-47102-48102-49Entities included in the consolidated
financial statements

Defining report content and topic
Boundaries
An explanation of the process for defining
https://www.comforiaa the report content and the topic
reit.co.jp/en/sustainability/materiality.html
Boundaries.
List of material topics
A list of the material topics identified in the https://www.comforiaa
process for defining report content.
reit.co.jp/en/sustainability/materiality.html
Restatements of information
Nothing in particular
Changes in reporting
Nothing in particular

102-50

Reporting period

102-51

Date of most recent report

Not applicable

Reporting cycle

https://www.comforiareit.co.jp/en/sustainability/disclosure.html

102-53102-54102-55102-56

TLC REIT Management Inc.is 100% subsidiary of
Tokyu Fudosan Holdings Corporation andsubjected to consolidated financial statements.

None

https://www.comforiareit.co.jp/en/sustainability/disclosure.html

102-52

Asset Manager
Location or reason for omission

Materiality

Materiality

https://www.tokyutrm.co.jp/en/sustainability/materiality.html
https://www.tokyutrm.co.jp/en/sustainability/materiality.html
Nothing in particularNothing in particular

Sustainability
https://www.tokyuinformation
disclosure and GRI trm.co.jp/en/sustainability/gri.html
Index
Not applicable
Sustainability
information
https://www.tokyudisclosure and GRI trm.co.jp/en/sustainability/gri.html
Index

Contact point for questions regarding https://www.comforiaContact us
the report
reit.co.jp/en/contact/index.html
Claims of reporting in accordance
Sustainability reporting is prepared with reference
to GRI standards
with the GRI Standards
GRI content index
GRI Content Index (this table)
Environmental Performance was assured by aExternal assurance
third-party organization
Sustainability
Report 2022 P.92
https://www.comforia(Independent
reit.co.jp/en/sustainability/disclosure.html
Assurance
Statement)

https://www.tokyu-trm.co.jp/en/contact/

Materiality

Materiality

Sustainability
information
disclosure and GRI
Index
Sustainability
information
disclosure and GRI
Index
Contact Us

Sustainability reporting is prepared with reference
to GRI standards
GRI Content Index (this table)
None

82

GRI Content Index

Disclosure

GRI 200: Economic
Management Approach
Explanation of the material topic and
103-1
its Boundary
The management approach and its
103-2
components
Evaluation of the management
103-3
approach
201: Economic Performance 2016
Financial implications and other risks
and opportunities due to climate
201-2
change

REIT
Location or reason for omission

https://www.comforiareit.co.jp/en/sustainability/materiality.html
https://www.comforiareit.co.jp/en/sustainability/examples.html
https://www.comforiareit.co.jp/en/sustainability/index.html

Risks and opportunities posed by climatechange that have the potential to generate https://www.comforiaa
reit.co.jp/en/sustainability/materiality.html
substantive changes in operations,revenue, or expenditure, including:https://dev.comforiareit.co.jp/en/sustainability/climate.html

Asset Manager
Location or reason for omission

Examples of
initiatives

https://www.tokyutrm.co.jp/en/sustainability/materiality.html
https://www.tokyutrm.co.jp/en/sustainability/esg.html

Promotion System

https://www.tokyu-trm.co.jp/en/sustainability/

Promotion System

Materiality

https://www.tokyutrm.co.jp/en/sustainability/materiality.html

Materiality

Materiality

Materiality
Our Commitment

Addressing Climate
Change205: Anti-corruption 2016
205-1

Since the investment corporation does not have
employees due to legal restrictions,Operations assessed for risks related
implementations by the asset management
to corruption
company's employees are applicable to this
topic.
Total number and percentage ofa operations assessed for risks related tocorruption.
Significant risks related to corruptionbidentified through the risk assessment.

１（The asset management company solely
operates at the Head Office）, 100%
None

83

GRI Content Index

Disclosure
205-2

Communication and training aboutanti-corruption policies andprocedures

REIT
Location or reason for omission
Since the investment corporation does not have
employees due to legal restrictions,
implementations by the asset managementcompany's employees are applicable to this
topic.

Asset Manager
Location or reason for omission
https://tokyu-fudosan-hdcsr.disclosure.site/en/themes/38※As a member of the Tokyu Land HoldingsGroup, we share the above policy

Total number and percentage ofgovernance body members that havedreceived training on anti-corruption,broken down by region.
Total number and percentage of
employees that have received training oneanti-corruption, broken down by employee
category and region.
Confirmed incidents of corruption and
205-3
No incidents
actions taken
206: Anti-competitive Behavior 2016
Legal actions for anti-competitive
206-1
behavior, anti-trust, and monopoly
No incidents
practices

GRI 300: Environmental
Management Approach
Explanation of the material topic and
103-1
its Boundary
The management approach and its
103-2
components
Evaluation of the management
103-3
approachhttps://www.comforiareit.co.jp/en/sustainability/materiality.html
https://www.comforiareit.co.jp/en/sustainability/examples.html
https://www.comforiareit.co.jp/en/sustainability/index.html

Anti-Corruption
Policy（Tokyu
Fudosan Holdings）

https://www.tokyutrm.co.jp/en/sustainability/esg.html#c4

ComplianceTraining

https://www.tokyutrm.co.jp/en/sustainability/esg.html#c4

ComplianceTraining

No incidents

No incidents

Materiality
Examples of
initiatives
Promotion System

https://www.tokyutrm.co.jp/en/sustainability/materiality.html
https://www.tokyutrm.co.jp/en/sustainability/esg.html
https://www.tokyutrm.co.jp/en/sustainability/index.html

Materiality
Our Commitment
Promotion System

84

GRI Content Index

302: Energy 2016

302-2

302-3

Disclosure

REIT
Location or reason for omission

Energy consumption outside of theorganization

https://www.comforiareit.co.jp/en/sustainability/disclosure.html

Energy intensity

https://www.comforiareit.co.jp/en/sustainability/disclosure.html

303: Water 2018

Water consumption

303-5

https://www.comforiareit.co.jp/en/sustainability/disclosure.html

Total water consumption from all areas inmegaliters.
305: Emissions 2016

Asset Manager
Location or reason for omission
Sustainability
Report 2022
P.22
(Environmental
Performance)
Sustainability
Report 2022
P.22
(Environmental
Performance)
Sustainability
Report 2022
P.22
(Environmental
Performance)

a

305-1

305-2

305-4

Direct (Scope 1) GHG emissions

https://www.comforiareit.co.jp/en/sustainability/disclosure.html

Energy indirect (Scope 2) GHG
emissions

https://www.comforiareit.co.jp/en/sustainability/disclosure.html

GHG emissions intensity

https://www.comforiareit.co.jp/en/sustainability/disclosure.html

307: Environmental Compliance 2016
Non-compliance with environmental
307-1
laws and regulations

No violations during the reporting period

Sustainability
Report 2022
P.22
(Environmental
Performance)
Sustainability
Report 2022
P.22
(Environmental
Performance)
Sustainability
Report 2022
P.22
(Environmental
Performance)
No violations during the reporting period

85

GRI Content Index

Disclosure

GRI 400: Social
Management Approach
Explanation of the material topic and
103-1
its Boundary
The management approach and its
103-2
components
Evaluation of the management
103-3
approach
401: Employment 2016
401-1

New employee hires and employee
turnoverTotal number and rate of new employee
a hires during the reporting period, by age
group, gender and region.
Total number and rate of employee
b turnover during the reporting period, by
age group, gender and region.

401-2

Benefits provided to full-time
employees that are not provided totemporary or part-time employees

401-3

Parental leave

REIT
Location or reason for omission

https://www.comforiareit.co.jp/en/sustainability/materiality.html
https://www.comforiareit.co.jp/en/sustainability/examples.html
https://www.comforiareit.co.jp/en/sustainability/index.html

Asset Manager
Location or reason for omission

Materiality
Examples of
initiatives
Promotion System

https://www.tokyutrm.co.jp/en/sustainability/materiality.html
https://www.tokyutrm.co.jp/en/sustainability/esg.html
https://www.tokyutrm.co.jp/en/sustainability/index.html

Materiality
Our Commitment
Promotion System

Since the investment corporation does not have
employees due to legal restrictions,
implementations by the asset managementcompany's employees are applicable to this
topic.

Since the investment corporation does not have
employees due to legal restrictions,
implementations by the asset managementcompany's employees are applicable to this
topic.
Since the investment corporation does not have
employees due to legal restrictions,
implementations by the asset managementcompany's employees are applicable to this
topic.

https://www.tokyutrm.co.jp/en/sustainability/esg.html#c3

Key Employee Data

https://www.tokyutrm.co.jp/en/sustainability/esg.html#c3

Key Employee Data

https://www.tokyutrm.co.jp/en/sustainability/esg.html#c3

Employee welfare
programs(representative
examples)

https://www.tokyutrm.co.jp/en/sustainability/esg.html#c3

Status of WorkStyle Reform andDiversity Promotion

86

GRI Content Index
Disclosure403: Occupational Health and Safety 2018403-2

Hazard identification, risk
assessment, and incident
investigation
A description of the processes used to
identify work-related hazards and assess
risks on a routine and non-routine basis,aand to apply the hierarchy of controls inorder to eliminate hazards and minimizerisks, including:A description of the policies andprocesses for workers to remove
themselves from work situations that theycbelieve could cause injury or ill health,and an explanation of how workers areprotected against reprisals.

403 -4403-5

REIT
Location or reason for omission
Since the investment corporation does not have
employees due to legal restrictions,
implementations by the asset managementcompany's employees are applicable to this
topic.

Asset Manager
Location or reason for omission

https://www.tokyutrm.co.jp/en/sustainability/esg.html#c3

Health Committee

Implementation of health committee, feedback
through workplace inspections by industrial
doctors, confirmation of working hours of all
officers and employees, implementation of
feedback and lectures based on periodic stresschecks, etc.
Lectures by industrial doctors, individualinterviews with industrial doctors, and feedback
to superiors

Worker participation, consultation,and communication on occupational
health and safety

Since the investment corporation does not have
employees due to legal restrictions,
implementations by the asset managementcompany's employees are applicable to this
topic.

Employees also take part in the health committee
disclosed below.
Health Committee
https://www.tokyutrm.co.jp/en/sustainability/esg.html#c3

Worker training on occupational
health and safety

Since the investment corporation does not have
employees due to legal restrictions,
implementations by the asset managementcompany's employees are applicable to this
topic.

Carrying out lectures by industrial doctors andplanned classes related to harassment.
https://www.tokyutrm.co.jp/en/sustainability/esg.html#c3

Various employee
training programs(examples ofrepresentative
cases)
Health Committee

Carrying out stress checks and regular healthchecks.
https://www.tokyutrm.co.jp/en/sustainability/esg.html#c3

Our Commitment
Status of WorkStyle Reform andDiversity Promotion

https://www.tokyutrm.co.jp/en/sustainability/esg.html#c3

Status of WorkStyle Reform andDiversity Promotion

403-6

Promotion of worker health403-9

Work-related injuries

Since the investment corporation does not have
employees due to legal restrictions,
implementations by the asset managementcompany's employees are applicable to this
topic.
Since the investment corporation does not have
employees due to legal restrictions,
implementations by the asset managementcompany's employees are applicable to this
topic.

87

GRI Content Index

Disclosure403-10Work-related ill health404: Training and Education 2016
404-1

404-2

404-3

REIT
Location or reason for omission
Since the investment corporation does not have
employees due to legal restrictions,
implementations by the asset managementcompany's employees are applicable to this
topic.

Since the investment corporation does not have
employees due to legal restrictions,Average hours of training per year per
implementations by the asset management
employeecompany's employees are applicable to this
topic.
Since the investment corporation does not have
Programs for upgrading employee
employees due to legal restrictions,skills and transition assistance
implementations by the asset managementcompany's employees are applicable to thisprograms
topic.
Percentage of employees receiving
regular performance and careerdevelopment reviews

Percentage of total employees by genderand by employee category who receiveda a regular performance and careerdevelopment review during the reporting
period.

Since the investment corporation does not have
employees due to legal restrictions,
implementations by the asset managementcompany's employees are applicable to this
topic.

Asset Manager
Location or reason for omission
https://www.tokyutrm.co.jp/en/sustainability/esg.html#c3

Status of WorkStyle Reform andDiversity Promotion

https://www.tokyutrm.co.jp/en/sustainability/esg.html#c3

Various employee
training programs(examples ofrepresentative
cases)

https://www.tokyutrm.co.jp/en/sustainability/esg.html#c3

Employee
Development

Both contracted employees and regular
employees receive performance and careerdevelopment reviews in the same structure, andPerformance
aim to set the goals and communicate with
Evaluation Processsuperiors.
https://www.tokyutrm.co.jp/en/sustainability/esg.html#c3
100%

88

GRI Content Index

Disclosure405: Diversity and Equal Opportunity 2016
Diversity of governance bodies and405-1
employees

REIT
Location or reason for omission

Asset Manager
Location or reason for omission

Percentage of individuals within thehttps://www.comforiaa organization’s governance bodies in each
reit.co.jp/en/about/profile.html
of the following diversity categories:

Officers

https://www.tokyutrm.co.jp/en/sustainability/esg.html#c3

i. Gender;

https://www.comforiareit.co.jp/en/about/profile.html

Officers

https://www.tokyutrm.co.jp/en/sustainability/esg.html#c3

ii. Age group: under 30 years old, 30-50
years old, over 50 years old;

https://www.comforiareit.co.jp/ja/about/profile.html

Officers(inJapanese)https://www.tokyutrm.co.jp/en/sustainability/esg.html#c3

Since the investment corporation does not have
Percentage of employees per employee employees due to legal restrictions,b category in each of the following diversity implementations by the asset management
categories:
company's employees are applicable to this
topic.

405-2

i. Gender;

https://www.tokyutrm.co.jp/en/sustainability/esg.html#c3

ii. Age group: under 30 years old, 30-50
years old, over 50 years old;

https://www.tokyutrm.co.jp/en/sustainability/esg.html#c3

iii. Other indicators of diversity where
relevant (such as minority or vulnerable
groups).

https://www.tokyutrm.co.jp/en/sustainability/esg.html#c3

Ratio of basic salary and remuneration There is no gender difference for each employee
of women to men
category.

There is no gender difference for each employee
category.

Key Employee Data
Status of WorkStyle Reform andDiversity Promotion
Key Employee Data
Status of WorkStyle Reform andDiversity Promotion
Key Employee Data
Status of WorkStyle Reform andDiversity Promotion

Key Employee Data
Status of WorkStyle Reform andDiversity Promotion
Key Employee Data
Status of WorkStyle Reform andDiversity Promotion
Key Employee Data
Status of WorkStyle Reform andDiversity Promotion

89

GRI Content Index

Disclosure
406: Non-Discrimination 2016
Incidents of discrimination and406-1
corrective actions takenaTotal number of incidents of
discrimination during the reporting period.

b

Status of the incidents and actions takenwith reference to the following:

411: Rights of Indigenous Peoples 2016
Incidents of violations involving
411-1
rights of indigenous peoples
412: Human Rights Assessment
412-2

Employee training on human rights
policies or procedures

REIT
Location or reason for omission

Asset Manager
Location or reason for omission

No incidents during the reporting period

No incidents during the reporting period

No incidents during the reporting period

No incidents during the reporting period

Since the investment corporation does not have
employees due to legal restrictions,
implementations by the asset managementcompany's employees are applicable to this
topic.

https://tokyu-fudosan-hdcsr.disclosure.site/en/themes/36※As a member of the Tokyu Land HoldingsGroup, we share the above Standards
https://www.tokyutrm.co.jp/en/sustainability/gri.html

Total number of hours in the reporting
period devoted to training on humana rights policies or procedures concerning
aspects of human rights that are relevant
to operations.
Percentage of employees trained during
the reporting period in human rightsb policies or procedures concerning
aspects of human rights that are relevant
to operations.

Labor Standards（Tokyu Fudosan
Holdings ）PAI Statement
P.5 Table 3 (9. Lackof a human rights
policy)90

GRI Content Index
REIT
Disclosure
Location or reason for omission
413： Local Communities 2016
Operations with local community
https://www.comforia413-1
engagement, impact assessments,
reit.co.jp/en/sustainability/examples.html
and development programs
Note: We report information on our
https://www.comforiaproperties in consideration of the purpose
reit.co.jp/en/sustainability/examples.html
of this standard.
414： Supplier Social Assessment 2016
New suppliers that were screened
No suppliers were screened during the reporting
414-1
using social criteria
periodNegative social impacts in the supply No suppliers were screened during the reporting
414-2
periodchain and actions taken
415: Public Policy 2016
415-1
Political contributions
No political contributions provided
416： Customer Health and Safety 2016
Assessment of the health and safety
https://www.comforia416-1
impacts of product and service
reit.co.jp/en/sustainability/examples.html
categories
Incidents of non-compliance416-2
concerning the health and safety
No violations during the reporting period
impacts of products and services
419: Socioeconomic Compliance 2016
Non-compliance with laws and419-1
regulations in the social andNo violations during the reporting period
economic area
GRI G4: Construction and Real Estate Sector Disclosures
Management Approach
Explanation of the material topic and https://www.comforia103-1
its Boundary
reit.co.jp/en/sustainability/materiality.html
The management approach and its
https://www.comforia103-2
components
reit.co.jp/en/sustainability/examples.html
Evaluation of the management
https://www.comforia103-3
approachreit.co.jp/en/sustainability/index.html
CRE
Type and number of sustainability
certification, rating and labelinghttps://www.comforiaschemes for new construction,
CRE8
reit.co.jp/en/sustainability/evaluation.html
management, occupation andredevelopment

Asset Manager
Location or reason for omission
Examples of
initiatives

https://www.tokyutrm.co.jp/en/sustainability/esg.html

Our Commitment

Initiatives in local
communities

https://www.tokyutrm.co.jp/en/sustainability/esg.html#c3

Contribution to theregionNo political contributions provided
Initiatives to improve https://www.tokyutenant satisfaction trm.co.jp/en/sustainability/gri.html

PAI Statement
P.6 4. Engagement
policies

No violations during the reporting period

Materiality
Examples of
initiatives
Promotion System

https://www.tokyutrm.co.jp/en/sustainability/materiality.html
https://www.tokyutrm.co.jp/en/sustainability/esg.html
https://www.tokyutrm.co.jp/en/sustainability/index.html

Materiality
Our Commitment
Promotion System

Environmental
Certification

91

Independent Assurance Statement92