PRINCIPAL ADVERSE IMPACT STATEMENT
The following is the adverse sustainability impact statement of Takara Leben Infrastructure Fund,Inc. (“TIF”) pursuant to Regulation (EU) 2019/2088 (“SFDR”). We have no employees inaccordance with the prohibition on having employees under the Act on Investment Trusts andInvestment Corporations of Japan and rely on Takara Asset Management Co., Ltd. (the “AssetManager”), to manage and operate the properties in our portfolio. TIF and the Asset Manager
are hereinafter referred to collectively as “we”, “us” or “our”.
1. Summary
We consider principal adverse impacts of our investment decisions on sustainability factors. The
present statement is our consolidated statement of the principal adverse impacts on sustainability
factors (“PAI”). The statement covers the reference period from December 1, 2020 to May 31,
2021. The statement will be reviewed at least once during every year.
Our sustainable investment objective is to build a high-quality portfolio of renewable energy
projects with a focus on solar energy projects. Further, we seek to contribute to the global
environment by building sustainable regional communities and promoting the use of renewableenergy. We also aim to create value by contributing to creation of employment opportunities andeconomic development, implementing measures against global warming and strengthening selfsufficiency in energy use. We use the definition of PAI as described in Recital 20 of SFDR being“those impacts of investment decisions and advice that result in negative effects on sustainabilityfactors”, with sustainability factors referring to environmental, social and employee matters,
respect for human rights, anti‐corruption and anti‐bribery matters as defined in article 2 (24) ofSFDR.
We believe that investment decisions that negatively affect climate or other environment-relatedresources, or have negative implications for society, can have a significant impact to risk andvalue creation for our unitholders. To this end, we consider the principal adverse impacts of ourinvestment decisions on the above sustainability factors throughout all major steps of theinvestment decision and management process throughout the lifecycle of the projects in ourportfolio. The application of this process is designed to ensure that investments do no significant
harm to any of the foregoing sustainability factors.
Please note that SFDR requirements, including the scope of their application to issuers outside
the European Economic Area, continue to evolve. We are therefore taking a principles-based
approach to compliance with the SFDR disclosure standards, which are subject to change.
2. Description of principal adverse sustainability impacts
Nearly all types of economic activity have the potential to impact various PAI indicators, both
positively and adversely. We aim to manage the risk connected to PAI from our investmentdecisions in several ways, including general screening criteria, due diligence and our ESG
initiatives. Some of the PAI indicators listed below are currently already being monitored andreported. As the availability of data improves, it is our intention that more indicators will beadded.

Table 1
Principal adverse sustainability impacts statement
We do not invest in investee companies, but invest in real estate. As adverse sustainability
indicators 1-16 as contained in the RTS pertain to investee companies, these are not included inthis PAI statement, which pertains to real estate investments.
Indicators applicable to investments in real estate assets
Adversesustainability
indicator

MetricImpact in2020

Impact in2019

Explanation

Actions taken

Fossilfuels

17.
Exposure
to fossil
fuels
through
real estate
assetsShare ofinvestments inreal estate
assets involvedin theextraction,
storage,transport ormanufacture offossil fuels

N/A

N/A

We do notinvest in realestate assets
involved in theextraction,
storage,transport ormanufacture offossil fuels. We
principally
consumeenergygenerated fromsolar energy
projects.
Accordingly,
we believe that
we do nosignificant
harm to thefossil fuels
factor.

N/A

Energyefficiency

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

As of May 31,
2021, all ofour properties
were “GreenProjects” (asdefined to theright).

As of May 31,
2020, all ofour properties
were “GreenProjects” (asdefined to theright).

Our entire
portfolio is
composed ofsolar energy
projects. Japan
Credit Rating
Agency, Ltd.
(“JCR”)
evaluates all ofour properties
as “GreenProjects”,
which meet thefollowing100% of the
projects in our
portfolio areGreenProjects.

eligible criteria:(i) all required
procedures
have been
confirmed andcompleted
underapplicable laws
and regulations
with respect toconstruction of
the project; (ii)no dispute
exists inrelation toacquiring theproject; (iii)
adequatemaintenancewill beconducted
throughoutsourced
O&M services;(iv) third-party
experts giveclean opinions
on whether the
project meets
their green
standards; and(v) futureenergy output
can becalculated andlong-termcarbon dioxide
reduction isexpected basedon projectedenergy output
by third party
experts.
Accordingly,
we believe that
we do nosignificant
harm to theenergy
efficiency
factor.

Table 2
Additional climate and other environment-related indicators
Adversesustainability
impactAdverse sustainability impact (qualitative or quantitative)

MetricIndicators applicable to investments in real estate assets
Energyconsumption

19. Energy consumption intensity
The amount of energy consumption of our assets per square meter was
0.23 kWh from August 1, 2020 to July 31, 2021.

Energy consumption
in kWh of our assets
per square meterAs 100% of our portfolio is invested in solar energy projects and we
principally consume energy generated from those projects, the amountof energy we draw from other energy sources is very low.
Accordingly, we believe that we do no significant harm to the energy
consumption factor.
At each of our projects that use extra-high voltage power, a chief
electrical engineer is stationed and promotes energy saving.

We consider the principal adverse impacts of our investment decisions on the above
sustainability factors throughout all major steps of the investment decision and management
process throughout the lifecycle of the projects in our portfolio. The application of this process isdesigned to ensure that investments do no significant harm to any of the foregoing sustainabilityfactors.

Table 3
Additional indicators for social and employee, respect for human rights, anti-corruption and antibribery matters
SOCIAL AND EMPLOYEE, RESPECT FOR HUMAN RIGHTS, ANTI-CORRUPTION AND ANTIBRIBERY MATTERS
Adversesustainability
impactAdverse sustainability impact (qualitative or quantitative)

Indicators applicable to investments to the Asset Manager or tenants

MetricSocial andemployee
matters

7. Incidents of discrimination
The Asset Manager emphasizes guarantee of basic human rights
and provides regular seminars on various topics such as power
harassment and sexual harassment, workplace communication,
methods for coping with harassment by customers, and measuresagainst harassment. The regular seminars are conducted at least
once a year and target the management positions.
The Asset Manager has implemented a whistle-blowing helplineand provides all of its employees with a pocket-size card about
the system so that they can easily report harassment and otherincidents. The helpline allows employees to access three different
resources: outside legal counsel, Takara Leben Co., Ltd.’s
corporate auditor and the Asset Manager’s Compliance Officer.
The Asset Manager also has strict disciplinary rules on
harassment.

1. Number of incidents
of discrimination
reported in investee
companies expressed as aweighted average
No incident ofdiscrimination has everbeen reported by the
Asset Manager’semployees.
2. Number of incidents
of discrimination leadingto sanctions in investee
companies expressed as aweighted average
No incident ofdiscrimination has everbeen reported by theAsset Manager’semployees.

14. Number of identified cases of severe human rights issues andincidents
The Asset Manager emphasizes the importance of guaranteeing
basic human rights and provides regular seminars on such topics.
Its whistle-blowing helpline, described above, is available toreport on issues concerning violation of human rights. The AssetManager’s management is also responsible for monitoring
workplace issues, including harassment.

Anti-corruption
and anti-bribery

15. Lack of anti-corruption and anti-bribery policies
We evaluate the operation and maintenance service providers, thefacility managers and the operators of our solar energy projects,
from anti-corruption and anti-bribery perspectives. If any suchservice provider is an unlisted company, we review publicly
available information related to the service provider before
entering into a business relationship and regularly conduct
surveys to check their internal controls with respect to anticorruption and anti-bribery policies.

Number of cases ofsevere human rights
issues and incidents
connected to investee
companies on a weighted
average basis
No case of a severe
human rights issue orincident has beenreported by the AssetManager’s employees.
Share of investments inentities without policies
on anti-corruption andanti- bribery consistent
with the United Nations
Convention against
Corruption
All of the operation andmaintenance service
providers, the facility
managers and theoperators of our solar
energy projects havepolicies on anti-corruption and antibribery.

For descriptions of actions which TIF takes and will take with respect to the PAI indicators,
please also refer to our ESG website with respect to TIF:
https://tif9281.co.jp/en/sustainability.html
3. Description of policies to identify and prioritize principal adverse sustainability impacts
Subject to data availability, we monitor the selected PAI indicators for the projects in ourportfolio.
Prior to our investment in a solar energy project, we conduct due diligence review of the project,including ESG due diligence, which includes selected PAI indicators. The due diligence findings
related to selected PAI indicators are reported and reviewed prior to the investment decision.
We review our sustainability policies, targets and measures at the Asset Manager’s Compliance
Committee and Investment Committee on an irregular base. For further information, please refer
to our ESG website: https://tif9281.co.jp/en/sustainability.html
4. Engagement policies
Due diligence and screening
The Asset Manager investigates the environmental and geological conditions of each project todetermine the possibility of environmental hazardous substances and land pollution in part basedon reports prepared by an expert that we believe to be nationally recognized in Japan for suchservices. The reports are based on publicly available documents and other information provided
primarily by the former owners or the former title-holders and property managers of the solar
energy projects. We ensure that we receive a quality review from an expert by reviewing, among
other factors, the expert’s independence and capabilities at the time of entering into a serviceagreement. Based on these reviews, which have been provided to us prior to our acquisition ofeach solar energy project and have not been updated, we believe the possibility that soil
contamination exists at the solar energy projects we intend to acquire is low based on
environmental laws and regulations relating to soil contamination in Japan. We do not invest in a
project with a possibility of environmental hazardous substances or land pollution unlessappropriate measures are taken under applicable laws and we confirm that any suchenvironmental issue has no adverse impact on the soil and the solar project.
We also investigate our projects from time to time in response to changes in our surroundingsocial and management environment. For example, recognizing the problem of forced labor inUyghur, we interviewed a solar panel manufacturer in China that provided solar panels to ourprojects regarding measures to protect human rights, and confirmed that the manufacturer had nomanufacturing hub in Uyghur and complied with our supplier code of conduct. When we need

reinforcement work at our projects to be disaster-ready, we retain consultants specializing indesign and development to review our projects and construct countermeasures as appropriate.
We also closely coordinate with the operator Takara Leben Co., Ltd. and the operation andmaintenance service providers on efforts to address environmental and social risks.
Engagement
We evaluate our business partners, including the operations and maintenance service providers,the facility managers and the operators of our solar energy projects, based on their complianceframeworks. We review publicly available information related to a business partner candidate
before entering into a relationship with it and conduct surveys to check their internal controls
once a year with respect to policies of antisocial forces or a whistle blowing system.
5. References to international standards
We follow the United Nations’ 17 Sustainability Development Goals, a reference frameworkadopted at the United Nations Summit held in September 2015.