BrightSpire Capital endeavors to conduct its commercial real estate finance investment practices, applying environmental, social, governance (“ESG”) and diversity, equity and inclusion (“DEI”) initiatives in business development, investment diligence, and governance and hiring practices.

The Company endeavors to conduct its commercial real estate lending and business practices to seek to: (1) incorporate ESG issues into investment analysis and decision-making processes; and (2) obtain appropriate disclosure on ESG issues by the entities in which it invests.

Goals

Diligence Priorities

Focus on sustainability certifications, energy management, air quality management, water and site management, natural and environmental concerns, and DEI policies, including governance codes of conduct (including anti-discrimination and harassment principles), unconscious bias and other training, and hiring, retention and leadership practices

Efficiently Manage Resources

Integrate leading ESG practices throughout our operations while collaborating with service providers, tenants and communities

Invest Responsibly

Build a resilient portfolio that reduces risks and recognizes opportunities to preserve resources while enhancing economic value

Building Long-Term Financial Value

Create long-term value for our stakeholders through responsible investing complementary to our investment mandates

Lead Transparently

Better understand counterparty commitment, measure and manage our business operations to improve environmental and financial performance

Create a Positive Impact

Make a positive, lasting impact in our global communities by working to improve the health and well-being of our employees and supporting charitable activities, including through a commitment to diversity, equity and inclusion in hiring and engagement practices

Environmental, Social & Governance (ESG)

We seek to improve operating performance by reducing energy, water use, waste and carbon emissions while lowering operating costs.

Our goal is to create a positive impact for our stakeholders and community through meaningful engagement, contribution and volunteerism.

We manage and operate our business by taking all of our stakeholders’ needs and values into consideration for long-term growth and sustainability.

The Company aims to build a sustainable future by creating economic value, preserving resources and improving the communities in which we operate. Primarily focused on senior loan originations in a competitive commercial real estate finance environment, the Company is mindful that normative and positive screening of borrower, sponsor, partner, vendor and service provider commitment to ESG standards (including diversity, equity and inclusion, or DEI) may positively contribute to the credit, risk and performance profile of the Company’s investments.

As a result, the Company has implemented diligence and periodic review protocols of borrowers, sponsors, partners, vendors and service providers to (i) better understand counterparty commitments made to ESG initiatives and, (ii) in return, educate and highlight to counterparties the relevance of ESG initiatives to the Company. In addition, the Company’s investment and portfolio management teams (x) evaluate the extent that environmental and sustainability initiatives are implemented by our borrowers/sponsors and in our target loan assets and (y) report their findings in our investment committee materials.

Norwegian Transparency Act of 2022

Norway introduced the Transparency Act (Åpenhetsloven) on 1 July 2022 with the desire to improve and facilitate more information regarding human rights and working conditions impacted by larger enterprises in Norway.  In connection with the Company’s investment in an office campus in Norway, applicable subsidiaries have prepared the following statement in accordance with such Transparency Act.

Norwegian Transparency Act Statement – (BRSP June 2023)