PAI Statement 2024.

Statement on Principal Adverse Impacts of Investment Decisions on Sustainability Factors

Financial market participant:
Storton Fund Management Ltd
LEI: 984500999A540457B545

Summary

Storton Fund Management Ltd (the “AIFM”) considers the principal adverse impacts of its investment decisions on sustainability factors in accordance with Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector (“SFDR”).

This statement constitutes the consolidated statement on principal adverse impacts on sustainability factors of Storton Fund Management Ltd. The statement covers the reference period from 1 January 2024 to 31 December 2024.

Storton Fund Management Ltd berücksichtigt die wichtigsten negativen Auswirkungen seiner Anlageentscheidungen auf Nachhaltigkeitsfaktoren. Diese Erklärung ist die konsolidierte Erklärung zu den wichtigsten negativen Auswirkungen auf Nachhaltigkeitsfaktoren von Storton Fund Management Ltd. Der Berichtszeitraum erstreckt sich vom 1. Januar 2024 bis zum 31. Dezember 2024.

Storton Fund Management Ltd considère les principaux impacts négatifs de ses décisions d’investissement sur les facteurs de durabilité. Le présent rapport constitue la déclaration consolidée relative aux principaux impacts négatifs sur les facteurs de durabilité pour la période allant du 1er janvier 2024 au 31 décembre 2024.

Storton Fund Management Ltd considera los principales impactos adversos de sus decisiones de inversión sobre los factores de sostenibilidad. La presente declaración consolidada cubre el período de referencia comprendido entre el 1 de enero de 2024 y el 31 de diciembre de 2024.

Description of Principal Adverse Impacts on Sustainability Factors

Indicators applicable to investments in investee companies

(Indicators, metrics, figures, explanations and actions remain unchanged and are reported in accordance with Annex I of Commission Delegated Regulation (EU) 2022/1288.)

Note: Where indicators are reported as zero, this reflects the nature of the underlying investments and the absence of exposure during the reference period.

(Table content retained as provided.)

Indicators applicable to investments in sovereigns and supranationals

Storton Fund Management Ltd did not have exposure to sovereign or supranational investments during the reference period. Accordingly, the relevant indicators are reported as zero.

Indicators applicable to investments in real estate assets

Fossil fuels

Storton Fund Management Ltd does not manage investments in real estate assets involved in the extraction, storage, transport, or manufacture of fossil fuels.

Energy efficiency

The indicator relating to exposure to energy-inefficient real estate assets has been calculated in accordance with the applicable RTS methodology, using EPC/BER certificates and year-end 2024 asset valuations.

The AIFM has set a target to improve the energy performance certification of approximately 5% of assets per annum from 2024 onwards. The reported 2024 figure reflects progress made against this objective.

Other Indicators for Principal Adverse Impacts

Greenhouse Gas Emissions

Scope 1, Scope 2, and Scope 3 emissions for real estate assets were calculated using data compiled with the support of third-party ESG specialists and in accordance with the GHG Protocol.

From 2024 onwards, Scope 2 emissions are reported on a market-based basis, including district heating where applicable. The AIFM continues to refine data availability, calculation methodologies, and data collection systems, while assessing the feasibility of emission-reduction initiatives.

The increase in emissions during the reporting period reflects, in part, changes in the asset base, including the acquisition and management of additional UK assets.

Waste and Biodiversity

Waste and biodiversity indicators were calculated on an asset-by-asset basis and aggregated at portfolio level. Year-on-year improvements have been recorded, and further initiatives are planned for the next reporting period.

Policies to Identify and Prioritise Principal Adverse Impacts

Storton Fund Management Ltd has adopted a Responsible Investment Policy, approved in 2024, which sets out its approach to responsible investment, ESG integration, and the identification and management of principal adverse impacts. This policy is reviewed at least annually.

The AIFM has also implemented supporting policies, procedures, and risk assessment tools to identify, monitor, and manage principal adverse impacts on an ongoing basis. Relevant indicators are selected in line with the nature of the underlying investments.

Additional social and employee indicators under Table 3 of Annex I are not reported where they are not applicable to real estate investments.

Integration Across the Investment Lifecycle

ESG considerations are integrated throughout the full investment lifecycle, from initial asset identification and acquisition, through the holding period, and ultimately to disposal.

All prospective investments are subject to due diligence processes that include an assessment of technical, environmental, and ESG-related risks. Identified risks are documented and considered as part of the investment approval process.

Data Availability and Methodology

The assessment of principal adverse impacts is dependent on data availability and quality. Storton Fund Management Ltd relies on multiple data sources and continues to enhance its data collection systems.

Where actual consumption data is available, it is used. Where such data is not available, reasonable estimates are applied in accordance with RTS guidance. Best efforts are made to improve data accuracy and reduce estimation uncertainty over time.

Engagement Policies

Tenants, suppliers, and service providers

The AIFM actively engages with tenants, suppliers, and service providers on ESG matters. In 2024, the first tenant survey was conducted, including ESG-related questions. Feedback received is being used to inform ongoing and future sustainability initiatives. A further tenant survey is planned for the second half of 2025.

Staff engagement

Storton recognises the importance of staff engagement on ESG topics. Staff surveys conducted in 2024 and 2025 included ESG-related questions, with results informing internal initiatives and awareness programmes.

Description of the principal adverse impacts on sustainability factors
Indicators applicable to investments in investee companies
Adverse sustainability indicator Metric Impact 2024 Impact 2023 Explanation Actions taken, and actions planned and targets set for the next reference period
Greenhouse gas emissions 1. GHG emissions Scope 1 GHG emissions 0 0 N/A N/A
Scope 2 GHG emissions 0 0 N/A N/A
Scope 3 GHG emissions 0 0 N/A N/A
Total GHG emissions 0 0 N/A N/A
2. Carbon footprint Carbon footprint 0 0 N/A N/A
3. GHG intensity of investee companies GHG intensity of investee companies 0 0 N/A N/A
4. Exposure to companies active in the fossil fuel sector{" "} Share of investments in companies active in the fossil fuel sector{" "} 0% 0% N/A N/A
5. Share of non-renewable energy consumption and production Share of non-renewable energy consumption and non-renewable energy production of investee companies from non-renewable energy sources compared to renewable energy sources, expressed as a percentage of total energy sources 0% 0% N/A N/A
6. Energy consumption intensity per high impact climate sector Energy consumption in GWh per million EUR of revenue of investee companies, per high impact climate sector 0% 0% N/A N/A
Biodiversity 7. Activities negatively affecting biodiversity-sensitive areas Share of investments in investee companies with sites/operations located in or near to biodiversity-sensitive areas where activities of those investee companies negatively affect those areas 0% 0% N/A N/A
Water 8. Emissions to water Tonnes of emissions to water generated by investee companies per million EUR invested, expressed as a weighted average 0 0 N/A N/A
Waste 9. Hazardous waste and radioactive waste ratio Tonnes of hazardous waste and radioactive waste generated by investee companies per million EUR invested, expressed as a weighted average 0 0 N/A N/A
INDICATORS FOR SOCIAL AND EMPLOYEE, RESPECT FOR HUMAN RIGHTS, ANTI-CORRUPTION AND ANTI-BRIBERY MATTERS
Social and employee matters 10. Violations of UN Global Compact principles and Organisation for Economic Cooperation and Development (OECD) Guidelines for Multinational Enterprises Share of investments in investee companies that have been involved in violations of the UNGC principles or OECD Guidelines for Multinational Enterprises 0% 0% N/A N/A
11. Lack of processes and compliance mechanisms to monitor compliance with UN Global Compact principles and OECD Guidelines for Multinational Enterprises Share of investments in investee companies without policies to monitor compliance with the UNGC principles or OECD Guidelines for Multinational Enterprises or grievance /complaints handling mechanisms to address violations of the UNGC principles or OECD Guidelines for Multinational Enterprises 0% 0% N/A N/A
12. Unadjusted gender pay gap Average unadjusted gender pay gap of investee companies 0% 0% N/A N/A
13. Board gender diversity Average ratio of female to male board members in investee companies, expressed as a percentage of all board members 0% 0% N/A N/A
14. Exposure to controversial weapons (anti-personnel mines, cluster munitions, chemical weapons and biological weapons) Share of investments in investee companies involved in the manufacture or selling of controversial weapons 0% 0% N/A N/A
Indicators applicable to investments in sovereigns and supranationals
Environmental 15. GHG intensity GHG intensity of investee countries 0 0 N/A N/A
Social 16. Investee countries subject to social violations Number of investee countries subject to social violations (absolute number and relative number divided by all investee countries), as referred to in international treaties and conventions, United Nations principles and, where applicable, national law 0 0 N/A N/A
Indicators applicable to investments in real estate assets
Fossil fuels 17. Exposure to fossil fuels through real estate assets Share of investments in real estate assets involved in the extraction, storage, transport or manufacture of fossil fuels 0% 0% Does not own assets involved in the extraction, storage, transport or manufacture of fossil fuels N/A
Energy efficiency 18. Exposure to energy-inefficient real estate assets Share of investments in energy-inefficient real estate assets 77% 83% This indicator has been calculated in accordance with the relevant formula using EPC/BER certificates and year end 2024 asset valuations We have set a target of improving the EPC scores of 5% of our assets per annum from 2024 onwards. Our 2024 number reflects this improvement.
Other indicators for principal adverse impacts on sustainability factors
Greenhouse gas emissions 19. GHG emissionss Scope 1 GHG emissions generated by real estate assets 750.51 tCO2e 28.37 tCO2e We used 3rd party ESG specialists to assess and compile our 2024 GHG emissions data. In 2024 we improved our data availability and refined the methodology used in our calculations. *From 2024 onwards Scope 2 reporting will reflect market-based emissions and district heating. We continue to refine our data collection systems whilst also reviewing the feasability of various GHG reduction initiatives. In addition, 2024 saw a substantial increase in UK assets acquired and managed.
Scope 2 GHG emissions generated by real estate assets 1,222.27 tCO2e* 4007.76 tCO2e
Scope 3 GHG emissions generated by real estate assets 31,473.46 tCO2e 15,778.44 tCO2e
Total GHG emissions generated by real estate assets 33,446.24 tCO2e 19,814.56 tCO2e
Waste 20. Waste production in operations Share of real estate assets not equipped with facilities for waste sorting and not covered by a waste recovery or recycling contrac 15% 20% Calculated on an asset by asset basis and then compiled Our 2024 calculation reflects a year on year improvement. For 2025, we will assess the possibility of implementing recycling where not already present
Biodiversity 21. Land artificialisation Share of non-vegetated surface area (surfaces that have not been vegetated in ground, as well as on roofs, terraces and walls) compared to the total surface area of the plots of all assets 91% 92% Calculated on an asset by asset basis and then compiled Our 2024 calculation reflects a year on year improvement. For 2025, we will assess the possibility of increasing the share of vegetated surface area.