2023 Sustainable Finance Framework

2023

Sustainable

Finance Framework

Published on 10 July 2023

Cromwell Property Group

acknowledges and pays respects to

past and present Traditional Custodians

and Elders of Australia.

We respect the cultural, spiritual, and

educational practices of Aboriginal and

Torres Strait Islander peoples.

CROMWELL SUSTAINABLE FINANCE FRAMEWORK

CONTENTS

INTRODUCTION

OVERVIEW TO CROMWELL PROPERTY GROUP

CROMWELL’S APPROACH TO SUSTAINABILITY

SUSTAINABLE DEBT GOVERNANCE

SUSTAINABLE FINANCE FRAMEWORK

PURPOSE OF THE FRAMEWORK

USE OF PROCEEDS INSTRUMENTS

SUSTAINABILITY-LINKED INSTRUMENTS

FRAMEWORK ASSURANCE

FURTHER INFORMATION

CONTACTS

DISCLAIMER

APPENDIX

LIST OF CURRENT ENTITIES

VERSION CONTROL

CROMWELL SUSTAINABLE FINANCE FRAMEWORK

OVERVIEW OF CROMWELL PROPERTY GROUP

Cromwell Property Group (ASX:CMW) (Cromwell) is a

real estate investor and fund manager with operations

on three continents and a global investor base. As at

31 December 2022, Cromwell had a market capitalisation

of $1.8 billion, an Australian investment portfolio valued

at $2.8 billion and total assets under management of

$12.0 billion across Australia, New Zealand and Europe.

Cromwell’s platform comprises 350+ staff in 20 offices

in 15 countries across Australia, New Zealand and Europe.

Total Assets Under Management (AUM) are AUD $12.0 /

€7.6 billion, diversely spread across a range of sectors

including Office (64%), Retail (9%), Industrial/Logistics

(20%), Property Securities (3%) and Other (4%). The portfolio

comprises 210+ assets let to more than 2,300 tenants.

$12.0billion 217

properties

350+

people

3.5million

sqm

countries

$8.1 billion

Total third-party AUM

$5.4 billion

Europe

$2.7 billion

Australia / New Zealand

oﬃces

20 2,300+

tenant customers

*As at 31 December 2022

INTRODUCTION

Broad Fund Management

Platform

Geographically and Culturally

Diverse Team

Global Asset Management

Expertise

CROMWELL SUSTAINABLE FINANCE FRAMEWORK

OUR CORPORATE VISION

A trusted, global real estate fund manager

recognised for our transparency, authenticity

and creativity

CROMWELL SUSTAINABLE FINANCE FRAMEWORK

ENVIRONMENT

SOCIAL

GOVERNANCE

PEOPLE PLACES & COMMUNITIES

Deliver resilient, revitalised

and sustainable asset

portfolios that generate value

and meet investor and other

stakeholder expectations.

Create a culture of

authenticity and creativity.

Build capability and diversity.

Nurture wellbeing.

Connect meaningfully to

build authentic relationships.

Generate value by meeting

our tenants’ evolving needs.

Contribute positively to the

communities we operate in.

Embed ESG across our

business. Manage opportunity

and risk by integrating

environmental and social

value in our decisions.

Demonstrate accountability

and transparency.

CROMWELL’S APPROACH TO SUSTAINABILITY

Cromwell has formalised an ESG Strategy. Our process for developing our new ESG Strategy has been one of consultation

and collaboration, and we have sought to achieve a globally harmonised approach. This strategy includes targets that are

crucial to our future, including decarbonising our business toward net zero and setting new baselines for areas such as

energy consumption, waste management, and carbon in each of our operating regions. We have also developed region

specific targets to ensure we are addressing local concerns, such as the development and registration of an Australian

Reconciliation Action Plan, with further progress and meaningful reflection occurring constantly.

OUR ESG VISION

Elevating real estate investment.

Empowering our people. Delivering a

resilient future for our investors, tenants,

communities, and planet.

CROMWELL SUSTAINABLE FINANCE FRAMEWORK

Some of our key group targets are

featured below:

Our annual materiality review is an important tool in

ensuring Cromwell responds appropriately to stakeholder

concerns. Our approach to materiality is guided by the Global

Reporting Initiative Standards.

We have used an independent third party to review

stakeholder feedback - along with our commitments and

policies, considering industry and peer performance - to

give us the most important topics to our long-term value.

Our methodology comprised a desktop review; stakeholder

interviews and survey; consolidation and prioritisation

of topics; and validation and reporting. The impact of

these material topics was also assessed against the UN

Sustainable Development Goals.

Our Group ESG Policy sets out our broad approach to ESG

related issues, including on climate change, emissions,

energy, waste, water and biodiversity management,

philanthropy and human rights.

Our annual materiality review is an important tool in

ensuring Cromwell responds appropriately to stakeholder

concerns. Our approach to materiality is guided by the Global

Reporting Initiative Standards.

We have used an independent third party to review

stakeholder feedback - along with our commitments and

policies, considering industry and peer performance - to

give us the most important topics to our long-term value.

Our methodology comprised a desktop review; stakeholder

interviews and survey; consolidation and prioritisation

of topics; and validation and reporting. The impact of

these material topics was also assessed against the UN

Sustainable Development Goals.

Our Group ESG Policy sets out our broad approach to ESG

related issues, including on climate change, emissions,

energy, waste, water and biodiversity management,

philanthropy and human rights.

Towards net zero

As a capital light fund manager that focuses on the

acquisition and uplift of existing buildings, we have a far

lighter carbon footprint – with our embodied carbon largely

limited to maintenance and refurbishment. During our

buildings’ lifecycles, we aim to act as responsible stewards –

we generally acquire existing buildings, doing what we can to

improve their environmental efficiency and ensure they are

performing well, before divestment.

In FY23, we developed a comprehensive Scope 1-3 emissions

baseline and Marginal Abatement Cost Curves across all

regions to understand where our major emissions sources

lie in our value chain, and determine and prioritise locally

appropriate and cost-effective emissions reduction activities.

We have now developed an ambitious Net Zero Strategy that

encompasses our Scope 3 emissions, including our tenants’

emissions and embodied carbon, and we are excited to share

updates on our progress.

Gender Pay Gap

We will signiﬁcantly reduce our gender pay

gap year on year.

Pay Parity

We will maintain pay parity.

Gender Diversity

We will achieve 40:40:20 gender diversity

at all levels.

Cultural Diversity

We will measure our cultural diversity.

Reconciliation

We will commence our Reconciliation

journey and develop a Reconciliation

Action Plan.

Diversity & Inclusion

Net Zero

Net zero operational control by 2035

Net zero Scope 1, 2 and 3, including

tenant emissions and embodied

carbon by 2045

100% by 2030 for operationally

controlled assets

Renewable Energy

ENVIRONMENT

PEOPLE

CROMWELL SUSTAINABLE FINANCE FRAMEWORK

Community conscious

Connected communities are better places to live, work,

and play. It is important to Cromwell that we engage and

enrich the local communities in which our properties

are located. Developing mature relationships within our

communities gives us the opportunity to play a proactive

role in growing and investing in local partnerships, including

those with Indigenous landowners in Australia. Positive local

relationships help us to meet the needs of the community

during construction and major refurbishment works and for

the tenants who occupy our buildings.

In FY22, Cromwell lodged an application with Reconciliation

Australia to create our first Reconciliation Action Plan (RAP)

to support our desire to contribute to the reconciliation

movement. The RAP will enable us to develop a structured

approach to advance reconciliation in ways relevant

to our business and reflecting the stage we are at in

our reconciliation journey. By committing to a Reflect

RAP, we are committing to the process of scoping and

developing relationships with Aboriginal and Torres Strait

Islander stakeholders.

Our people

At Cromwell, we believe our people are our greatest

strength. Retaining valued existing team members, and

attracting a diverse range of high calibre new talent,

strengthens our business and improves Cromwell’s ability

to partner and collaborate with all our stakeholders. It

is important that we have a strong employer brand – as

well as an employee value proposition that encompasses

recognition, professional growth, and flexibility.

We are committed to being an equal and inclusive workplace.

During FY22, we achieved our global objective of at least 40%

women for our Board, team leaders and emerging leaders.

It is our intention to reach this benchmark at all employee

levels by 2026.

We have adopted a new diversity and inclusion strategy and

have established internal diversity and inclusion committees

in each of our regions. Cromwell’s five-year strategy sets

our inclusion and diversity goals and initiatives to 2026. Our

targets address both engagement on diversity and inclusion,

gender diversity at all leadership levels, reducing the gender

pay gap, and cultural diversity.

CROMWELL SUSTAINABLE FINANCE FRAMEWORK

Cromwell’s recent achievements

In FY23 we have continued to accelerate our commitments in sustainability.

Some achievements include:

• We achieved outstanding results in our energy and water portfolio

performance in the NABERS Sustainable Portfolio Index (SPI) 2023. Two

of our funds, Cromwell Direct Property Fund and Cromwell Diversified

Property Trust, ranked 3rd and 4th best office portfolios overall in Australia.

The NABERS Sustainable Portfolios Index (SPI) showcases leading

property portfolios across Australia according to their NABERS ratings and

percentage of portfolio rated. The SPI is globally unique in that it provides

a public, whole portfolio view of actual performance in terms of emissions

and water usage, and it tracks progress over time.

• We were included on the Dow Jones Sustainability Australia Index (DJSI)

for the first time in FY23, one of only eight property companies in Australia

to achieve this. The DJSI Australia is composed of sustainability leaders as

identified by S&P Global through the Corporate Sustainability Assessment

(CSA), representing the top 30% of companies in the S&P/ASX 200 based

on long-term economic, environmental, and social criteria.

• Cromwell became a signatory to the United Nations Principles for

Responsible Investment (PRI), cementing our commitment to integrating

ESG considerations into our investment decisions and active ownership

practices.

• We have improved or maintained our Global Real Estate Sustainability

Benchmark (GRESB) scores for our key funds each year since first

undertaking the assessment in 2017. The GRESB Real Estate Assessment

is an investor-driven global ESG benchmark and reporting framework to

validate, score and benchmark ESG performance data.

• Since 2019, Cromwell’s Australian operations have been certified

Carbon Neutral by Climate Active. Climate Active certification is awarded

to businesses and organisations that have achieved a state of carbon

neutrality.

Further details on our approach to sustainability, including our latest ESG

Report, can be found https://www.cromwellpropertygroup.com/sustainability.

SUSTAINABLE DEBT GOVERNANCE

The Cromwell Board has ultimate responsibility for the Sustainable Finance

Framework (the “Framework”) and green or sustainability linked debt issued

under this framework. The ESG and Risk Committee (ERC), a sub-committee

of the Cromwell Board, has oversight of Cromwell’s ESG Strategy, Sustainable

Finance Framework and all matters relating to sustainable debt. This includes

pre-issuance approval of all sustainable debt instruments, their ongoing

performance against targets and reporting. The ERC meets on a quarterly basis

or ongoing as required, and reports to the Board annually on its activities.

For sustainable debt issued under the Cromwell European Real Estate

Investment Trust (CEREIT) Green Finance Framework, the CEREIT Board

has ultimate responsibility and strategic oversight through the CEREIT

Board Sustainability Committee and the CEREIT Management Sustainability

Committee. Debt proceeds issued under this Framework and the CEREIT Green

Finance Framework will not be mixed or counted together. CEREIT may elect

to adopt this framework for new bonds and loans, or in future after their bonds

and loans issued under the CEREIT Green Finance Framework have reached

maturity. For further information on the CEREIT Green Finance Framework,

please refer to CEREIT’s sustainability website:

https://www.cromwelleuropeanreit.com.sg/sustainability.

Cromwell’s Sustainable Finance Framework is referenced where appropriate in

the Cromwell Group Treasury Risk Management Policy.

2022

ESG REPORT

CEREIT GREEN

FINANCE FRAMEWORK

ESG Report

2022

2022 | CEREIT GREEN FINANCE FRAMEWORK

CEREIT

Green Finance

Framework

MARCH 2022

CROMWELL SUSTAINABLE FINANCE FRAMEWORK

SUSTAINABLE FINANCE

FRAMEWORK

PURPOSE OF THE FRAMEWORK

Cromwell Property Group has developed its Sustainable Finance Framework to support and provide transparency to

Cromwell’s commitment to fund low carbon, efficient and resilient buildings that meet the ESG ambitions of Cromwell and

its suppliers and customers through the use of sustainable debt instruments. Cromwell may raise or issue the following

sustainable debt instruments in accordance with applicable current market standards:

SUSTAINABLE DEBT

INSTRUMENT USE OF PROCEEDS MARKET STANDARDS

Use of proceeds

instruments: Green Bonds

and Loans

Net proceeds must be allocated

towards identified assets or

activities identified as eligible in this

Framework

International Capital Market Association (ICMA) Green

Bond Principles (GBP), Loan Market Association (LMA)

Green Loan Principles (GLP), Climate Bonds Initiative (CBI)

Climate Bonds Standard & Certification Scheme (CBS)

Sustainability-linked

instruments: Sustainability

Linked Bonds and Loans

Proceeds can be used for general

corporate purposes

ICMA Sustainability-Linked Bond Principles (SLBP), LMA

Sustainability-Linked Loan Principles (SLLP)

These voluntary standards are developed in multi-stakeholder processes involving issuers, investors, financial institutions

and NGOs, with a view to promoting the development and integrity of the sustainable finance market. Cromwell and all

its managed funds and joint ventures across Australia, New Zealand, Singapore, and Europe may raise debt under this

Framework for eligible assets that meet the eligible categories and eligibility criteria described over the following pages.

Noting it may be updated from time to time, a list of Cromwell’s current entities can be found in the appendix.

As these principles and guidelines, and the sustainable financing market overall, are evolving rapidly, this Sustainable

Finance Framework may be updated at Cromwell’s discretion to extend to the issuance of other sustainable debt instruments

that may be issued in the future and to remain in line with market best practice. Any future updated versions of this

Framework will either keep or improve the current levels of transparency and reporting disclosures.

CROMWELL SUSTAINABLE FINANCE FRAMEWORK

USE OF PROCEEDS INSTRUMENTS

Use of proceeds instruments refer to Green Bonds and Green Loans, where proceeds are exclusively applied to finance or

re-finance new and existing green assets or projects.

This section of the Framework takes into account the core components of the Green Bond Principles

and the Green Loan

Principles

, including:

1. Use of Proceeds

2. Process for Project Evaluation and Selection

3. Management of Proceeds

4. Reporting

Where appropriate, specific bonds and loans may be structured to be compliant with, and receive Certification under the

Climate Bonds Standard & Certification Scheme (CBS).

Use of proceeds

An amount equivalent to the net proceeds from Green Bonds or Loans issued pursuant to this Framework will be allocated

to finance or refinance, in part or in full, new and existing assets, projects or activities which meet the eligibility criteria

outlined below.

Each category has also been aligned to relevant UN Sustainable Development Goals

(SDG). On a best effort basis,

Cromwell Property Group may take into consideration applicable regional taxonomies

for buildings where available,

relevant, and feasible.

This list is not exhaustive and may be expanded over time as market standards are updated.

GLP AND GBP

ELIGIBLE CATEGORY ELIGIBILITY CRITERIA

SDG

Green buildings

Existing, planned or refurbished buildings or portfolios which meet one of the

following regional, national or internationally recognised standards or certifications for

environmental performance:

• Green Building Council of Australia Green Star “Design and/or As Built” and/or

“Performance” rating of minimum 5 Stars;

• NABERS, either of the following:

• Individual properties with a NABERS Energy rating of minimum 5 Star; OR

• Assets, projects or portfolios that meet the criteria outlined in the NABERS

Sustainable Finance Framework for building upgrades or low carbon

portfolios

;

• Building Research Establishment Environmental Assessment Method (BREEAM)

certification of minimum “Very Good”;

• Leadership in Energy and Environmental Design (LEED) certification of minimum

“Gold”;

• Energy Performance Certificate (EPC) of A or B for European buildings;

• Commercial office buildings certified to the CBS Sector Criteria for Buildings ––

Commercial Buildings Criteria;

• Upgrade projects, including energy efficiency investments and refurbishments,

which achieve a minimum 30% carbon emissions reduction against a business-as-

usual baseline;

• Any other assets that obtain a green building certification equivalent to the above.

Renewable energy

• Photovoltaic solar arrays on-site and dedicated support infrastructure and

expenditures;

• Installation, maintenance and repair of solar photovoltaic, wind turbines, hydrogen,

geothermal technology or energy storage.

1. ICMA Green Bond Principles 2021

2. APLMA/LMA/LSTA Green Loan Principles February 2023

3. https://sdgs.un.org/goals

4. Cromwell may seek alignment to regional taxonomies such as the EU Taxonomy and regional benchmarks such as the Deepki Real Estate ESG Index.

5. The building upgrades criteria is based on a building or portfolio achieving at least 30% reduction in emissions over a loan period. The low carbon portfolios

criteria recognises portfolios (2 or more buildings) that are performing in the top 15% of their cohort. Further information on the NABERS Sustainable Finance

Framework can be found here: https://www.nabers.gov.au/sites/default/files/nabers_sustainable_financial_framework.pdf

CROMWELL SUSTAINABLE FINANCE FRAMEWORK

Process for project evaluation and selection

The Cromwell Green Finance Committee (the

“Committee”) comprises members of the Investment

Committee, Treasury, Property and ESG team. The

Treasurer is ultimately responsible for compliance with the

Cromwell Sustainable Finance Framework. This includes

the following:

1. Ensuring that proceeds from Green Bonds and Loans

are earmarked for financing projects that meet the

above eligibility criteria;

2. Identifying, evaluating, selecting and scheduling

projects that meet the eligibility criteria;

3. Managing Green Bonds and Green Loans on issue;

4. Removing any projects that no longer meet the

eligibility criteria or have been disposed of, and

replacing them with new projects as soon as feasible;

5. Managing external reviews, including pre-issuance,

post-issuance and annual assurance by an approved

verifier against the relevant standards and compliance

with certification;

6. Validating reporting requirements;

7. Maintaining the Sustainable Finance Framework

to remain up to date with the evolving sustainable

financing market and the latest legislation, standards

and best practice.

Management of proceeds

The net proceeds from each Green Bond and Loan will be

managed by Cromwell’s Treasury team. They will maintain

an internal register outlining:

• Funding transaction:

- Issuer entity, transaction date, principal amount

of proceeds, maturity date, interest or coupon, the

ISIN number (if applicable)

• Use of Proceeds:

- Notional amount allocation of net proceeds from

any Green Bond or Loan

- Aggregate amount of proceeds earmarked to

eligible assets

- Remaining balance of unallocated proceeds yet to

be earmarked

• Other information:

- The value of each asset and other details on the

assets to which the proceeds of the transaction

have been allocated in accordance with

the Framework

- Compliance with the eligibility criteria

It is Cromwell’s intention to maintain an aggregate amount

of assets that is at least equal to the aggregate net proceeds

of all Green Bonds and Loans that are concurrently

outstanding. However, there may be periods when a

sufficient aggregate amount of assets have not yet been

allocated to fully cover an amount equal to the net proceeds

of all outstanding Green Bonds and Loans, either as the

result of changes in the composition of the Green Portfolio

or the issuance of additional Green Bonds and Loans. Any

such portion of the net proceeds that have not been allocated

to the Green Portfolio will be maintained in cash and cash

equivalents.

Payment of principal and interest will be made from

Cromwell’s securitisation vehicle general funds and will not

be directly linked to the performance of the Green Portfolio.

Cromwell will aim to fully allocate the proceeds within 12

months after the issuance date of each Green Bond or Green

Loan and will strive to maintain full allocation until maturity

by replacing any projects that may have been divested or are

no longer eligible due to other circumstances.

All relevant information regarding the issuance of Green

Bonds and Loans and the projects in the Green Portfolio (re)

financed will be monitored and maintained in Cromwell’s

internal records.

CROMWELL SUSTAINABLE FINANCE FRAMEWORK

Reporting

General Reporting:

Cromwell recognises the importance of transparency and disclosure and will make the following information available to

relevant lenders and/or bondholders as required:

ITEM FREQUENCY

Climate Bonds

Initiative Certification

(if applicable)

Pre-issuance and post-issuance of any CBS-certified Green Bonds or Loans.

Use of Proceeds

reporting

Annually for all outstanding Green Bonds or Loans. This includes:

• A list and description of the eligible assets being financed or refinanced;

• The amount of net proceeds allocated to earmarked eligible assets;

• Disclosure of unallocated proceeds;

• Confirmation that assets in the Green Portfolio meet the eligibility criteria under this Framework

including information on the characteristics and performance of the eligible assets;

• Where applicable, impact reporting will be incorporated within “Use of Proceeds” reporting.

Impact Reporting:

Where applicable and on a best efforts basis, impact reporting will be incorporated within annual reporting. Cromwell intends

to align impact reporting with the portfolio approach described in the ICMA “Handbook – Harmonised Framework for Impact

Reporting (June 2022)”. Cromwell may provide qualitative descriptions of outcomes and impacts of selected eligible assets

and projects funded, and quantitative reporting on relevant indicators. Where relevant, information will be provided on the

impact assessment and data reporting methodologies applied by Cromwell. Examples of possible environmental indicators

include:

ITEM POTENTIAL IMPACT METRICS

Green buildings

• Level of certification or rating (e.g. Green Star As-Built Rating, NABERS Energy Rating, EPC,

BREEAM rating) by property

• Percentage of total property portfolio which has achieved the minimum certification or rating

described in the eligibility criteria

Renewable energy

• On-site solar generation capacity (MW)

• On-site and off-site renewable electricity generation and usage (MWh) and as a percentage of total

energy consumption

Energy efficiency

• Annual greenhouse gas emissions (tCO2e) per total property footprint

• Percentage reduction in energy consumption against baseline

External review

An independent, recognised external party will verify the internal tracking method and allocation of funds, confirming that

an amount equivalent to the net proceeds of the Green Bond or Loan have been allocated in compliance with all material

respects of the eligibility criteria set forth in the Sustainable Finance Framework. Cromwell may seek external verification on

all annual reporting, until full allocation of the proceeds from any Green Bond or Loan issuance has been achieved. Cromwell

is committed to transparency and will make assurance reports available to relevant lenders and/or bondholder.

CROMWELL SUSTAINABLE FINANCE FRAMEWORK

SUSTAINABILITYLINKED INSTRUMENTS

This section relates to Sustainability-Linked Bonds and Sustainability-Linked Loans, where the cost of borrowing is linked

to Cromwell’s performance against predetermined Sustainability Performance Targets (SPTs) material to Cromwell’s ESG

Strategy. Proceeds from these instruments are utilised for general corporate purposes.

This section of the Framework takes into account the core components of the Sustainability-Linked Loan Principles

and

the Sustainability-Linked Bond Principles

, including:

1. Selection of KPIs

2. Calibration of SPTs

3. Loan and Bond Characteristics

4. Reporting

5. Verification

Selection of KPIs

KPIs will be selected on the basis that they are core, material and relevant to Cromwell’s ESG Strategy and of high

strategic significance to Cromwell’s current and future operations. Comparability against peers, benchmarks and

consistency in calculation methodology will also been taken into consideration. Example KPI themes which may be used

for potential target setting for the issuance of Sustainability-Linked Bonds or Loans include:

1. https://www.lsta.org/content/sustainability-linked-loan-principles-sllp/

2. https://www.icmagroup.org/sustainable-finance/the-principles-guidelines-and-handbooks/sustainability-linked-bond-principles-slbp/

Environmental

Places & Communities

GovernanceSocial

People

Note the above KPI themes is not an exhaustive list, are indicative only and may be amended over time in future

versions of this Framework.

Example potential KPI themes

• Carbon emissions

reduction

• Renewable electricity

usage

• Emissions intensity

• Green building

certifications and

environmental

performance ratings (e.g.

NABERS, Green Star,

BREEAM, or LEED)

Example potential KPI themes

• ESG screening of suppliers

and tenants

• External ESG performance

benchmarks (e.g. GRESB)

Example potential KPI themes

• Gender diversity and

equality

• Health and wellbeing

certification

• Procurement spend with

local businesses, social

enterprises or Indigenous-

owned businesses

CROMWELL SUSTAINABLE FINANCE FRAMEWORK

Calibration of SPTs

SPTs will be determined based on consistency with the

Cromwell ESG Strategy approved by Cromwell’s Board, set

with appropriate ambition and timeframe and specified in

the relevant documentation for each Sustainability-Linked

Loan or Bond together with any material factors that may

impact the achievement of the SPTs. Targets will be set with

reference to historical performance, peer performance or

regional, national or international targets and negotiated

with the relevant lender group and determined on either an

asset or portfolio basis. All calculation methodologies will

also be disclosed in the relevant documentation.

Sustainability-Linked Loan and Bond Characteristics

Proceeds of any of Cromwell’s Sustainability-Linked Loans

and Bonds will be available for general corporate purposes

unless otherwise stated. These transactions will feature

financial or structural characteristics which encourage the

achievement of the relevant SPTs, including incentives if the

SPTs are met and penalties if they are not, depending on

the transaction. The financial or structural characteristic

will be meaningful and aligned with market practice. The

magnitude of the pricing adjustment, as well as the effective

trigger event date(s), will be clearly detailed in the relevant

documentation for each transaction.

Reporting

Cromwell is committed to transparency and will clearly state

the scope, detail and frequency of reporting in the relevant

documentation for each Sustainability-Linked Bond or Loan.

For Sustainability-Linked Bonds, at a minimum, the relevant

Cromwell fund will undertake annual reporting regarding the

issuance and performance in relation to the SPTs and will

make such reporting available on its website or to lenders as

required by market standards.

For Sustainability-Linked Loans, on origination, the relevant

Cromwell fund and the arranging banks will agree on the

appropriate reporting frequency, format and timing for

disclosing information on sustainability performance to the

lender(s). Cromwell will provide updates to lenders at least

once annually thereafter.

Verification

To provide certainty on alignment to the SLLP and SLBP,

for each Sustainability-Linked Loan or Bond on issue,

appropriate external review will be undertaken. This includes

obtaining a second party opinion on each Sustainability-

Linked Bond or Loan individually as well as ongoing annual

post-issuance assurance of sustainability performance in

relation to the selected SPTs for each instrument. Post-

issuance assurance will cover any material change to the

KPI methodology or SPT calibration, if applicable.

FRAMEWORK ASSURANCE

Cromwell appointed DNV to provide an independent second

party opinion that this Framework and eligible assets in the

Green Portfolio align to the Green Bond Principles and the

Green Loan Principles. The second party opinion is available

on the Cromwell corporate website.

CROMWELL SUSTAINABLE FINANCE FRAMEWORK

FURTHER

INFORMATION

Further information on Cromwell’s approach to sustainability can be found

at: https://www.cromwellpropertygroup.com/sustainability.

CONTACTS

Cromwell welcomes feedback on this Framework from investors, lenders and stakeholders. Please use the contact

information below.

Post: Level 19, 200 Mary Street, Brisbane QLD 4000

Email: sustainability@cromwell.com.au

DISCLAIMER

This material is prepared for discussion only and should not be relied upon for any other purposes. It should not be

considered to be investment advice or a promotion or offer of any Cromwell products or services. It reflects the view of its

author at the date of publishing.

CROMWELL SUSTAINABLE FINANCE FRAMEWORK

APPENDIX

LIST OF CURRENT ENTITIES

Debt may be raised under this Framework by Cromwell and the following funds:

Australia:

• Cromwell Diversified Property Trust (DPT);

• Cromwell Direct Property Fund (DPF)

• Cromwell Riverpark Trust;

• Cromwell Property Trust 12;

• Cromwell Phoenix Property Securities Fund;

• Cromwell Phoenix Opportunities Fund;

• Cromwell Phoenix Global Opportunities Fund;

New Zealand:

• Funds of Oyster Property Funds Limited (joint venture);

Europe:

• Cromwell Polish Retail Fund (CPRF);

• Cromwell European Real Estate Investment Trust (CEREIT);

• Cromwell Italy Core Fund;

• Cromwell Italy Urban Logistics Fund;

• Cromwell Logistics Fund;

• Cromwell Italy Value Add Logistics Fund 1 & 2;

• Cromwell Wooden Building Fund;

• Funds of Stirling Development Agency Limited (joint venture).

Cromwell may update this list at any time.

VERSION CONTROL

UPDATES MADE DATE

Version 1.0 3 July

CROMWELL SUSTAINABLE FINANCE FRAMEWORK