The real estate industry contributes significantly to the climate, as it is responsible for around one third of CO² emissions. The commercial real estate sector in Germany, in which CCI is increasingly active, is of particular importance here. Although this represents only 10% of the current building inventory, it accounts for about half of the emissions. With this in mind, CCI sees the obligation to take measures in its everyday business to promote climate protection and thus ensure an environmentally sustainable future. CCI endeavours to act in an environmentally conscious and resource-saving manner, both in its original field of business, the granting of mezzanine loans for real estate project developments within Germany, and at the corporate level. The aim is to make its own contribution to climate protection, in particular to the reduction of greenhouse gas emissions and the generation of energy savings.

In their daily work, all employees* are regularly encouraged to conserve resources, especially energy and water. In addition to the responsible use of heating and cooling equipment in the offices, the behaviour with regard to the production of packaging waste and active waste separation as well as the consumption of resources and thus the CO² footprint must be questioned and adjusted. Avoiding unnecessary business travel is also one of the measures to actively contribute to climate protection. Furthermore, CCI supports the use of local public transport by providing employees with the Bahncard 25 as well as tickets for local public transport at their place of work. The provision of company vehicles is also regularly reviewed in this context, particularly with regard to the CO² emissions of the vehicles, and adjusted if necessary.

Every day, CCI is aware of its social responsibility towards employees, debtors and investors as well as other stakeholders in the real estate industry. All recognised labour law standards are adhered to in the office and workplace. This and other measures (training events and seminars, office equipment, etc.) ensure occupational safety and health protection. Adequate remuneration, fair conditions at the workplace, diversity and training and development opportunities are actively promoted by CCI.

When dealing with investors and debtors, comparable requirements for social behaviour within the respective companies are assumed, such as:

• the minimum wage requirements for workers in the construction industry,
• fair dealings with all stakeholders in projects under development as well as investments,
• diversity in the selection of potential tenants as well as construction companies,
• promotion of the regional economy,
• concrete measures to ensure health and safety at work.

With a forward-looking management approach, CCI seeks to establish a sustainable governance structure in the company. This includes:

• Measures to prevent corruption and money laundering
• Basis and possibility for whistleblowing in cases of wrongdoing
• Ensuring workers' rights and data protection

Compliance-conformant and compliance-aware behaviour on the part of the management and all colleagues is intended to prevent corruption and to prevent money laundering in general. The latter is additionally guaranteed by an external money laundering officer (Dr. Feiler (attorney-at-law), GSK Stockmann). In addition, a conflict-of-interest register is kept, which offers the opportunity to address conflicts and formulate solutions at an early stage.

Furthermore, all employees are given the opportunity to actively contribute to the company with suggestions for improvements at any time.

With respect to investors and debtors, CCI also ensures that they provide for appropriate governance structures analogous to CCI, such as, among others:

• compliance with generally accepted ESG standards, in particular the exclusion of certain industries, such as gambling or the arms industry, as well as the reduction of CO² emissions,
• measures to prevent corruption and money laundering,
• basis and possibility for whistleblowing in cases of wrongdoing,
• ensuring workers' rights and data protection.

All activities that serve to implement the ESG strategy within CCI's day-to-day business are constantly scrutinised, checked for effectiveness and optimised if necessary. In addition to the management, all stakeholders (employees, debtors, investors, etc.) are called upon to participate in this quality assurance process and to consistently expand and improve the catalogue of measures and thus the strategy. CCI thus pursues a dynamic approach that attempts to proactively meet this overall social obligation and to set the course for a sustainable and socially acceptable future in the long term.

1. Presentation of the strategic handling of sustainability risks (Art. 3 SFDR)

   CCI will not only include relevant financial risks in investment decisions as part of its investment processes, it will also consider material sustainability risks.

   For example, when granting loans, CCI attaches importance to project developers or property developers meeting the current requirements of the Building Energy Act (GEG) in their construction projects and preferably achieving high certification levels (DGNB, LEED, BREEAM, etc.). In addition, CCI is guided by the guidelines of the EU Action Plan on Sustainable Finance and, in particular, the requirements of the Taxonomy Regulation. This enables CCI, although it is not directly involved in the construction process as a financier, to work within its own investment decision-making processes to ensure that the financed projects meet the current standards of sustainable and energy-saving real estate. Furthermore, CCI favours refurbishments and renovations instead of demolition/new construction projects, provided that an existing building structure permits this. This is intended to stimulate the closed-loop economy, i.e. the reuse of certain resources, and to increase the useful life of real estate. In addition, CCI makes sure that debtors use sustainable building materials (e.g. with FCS seal) in order to also promote environmental protection in active new construction.

2. Presentation of the strategic handling of sustainability risks in relation to remuneration components (Art. 5 SFDR)

   All managing directors and employees of CCI are currently provided to the company by its parent company, Competo Capital Partners GmbH, on the basis of an intra-group service and provision agreement. It is transparently regulated that CCI does not act as an employer and that the managing directors and employees placed with it therefore do not receive any remuneration from it, but continue to be remunerated exclusively by Competo Capital Partners GmbH. Against this background, CCI does not currently pay any remuneration to directors or employees and has refrained from establishing its own remuneration policy, which would currently have no scope of application anyway. However, should CCI employ directors or employees as an employer in the future and remunerate them itself, it will draw up a remuneration policy in which sustainability risks in the areas of environment, social affairs and corporate governance are taken into account in an appropriate manner.

3. Presentation of adverse sustainability impacts (Art. 4 SFDR)

   At the current time, CCI does not yet take into account at the company level the principal adverse impacts of investment decisions on sustainability factors, i.e. adverse impacts in particular on environmental, social and labour concerns, respect for human rights and the fight against corruption and bribery (so-called „Principal Adverse Impacts“). Due to the considerable legal uncertainties in this respect at the current time with regard to the concrete requirements for measuring and reporting these adverse effects, CCI has decided to wait for further legal developments and to implement corresponding processes at a later date.